Miranda et al v. Office of the Commissioner of Baseball et al

Filing 32

ORDER by Judge Haywood S. Gilliam, Jr. Granting 25 Stipulation BRIEFING SCHEDULE AND PAGE LIMITS. (ndr, COURT STAFF) (Filed on 3/10/2015)

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KEKER & VAN NEST LLP
JOHN W. KEKER - #49092
[e-mail]
R. ADAM LAURIDSEN - #243780
[e-mail]
THOMAS E. GORMAN - #279409
[e-mail]
DAVID J. ROSEN - #296139
[e-mail]
633 Battery Street
San Francisco, CA 94111-1809
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendants

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ALAN M. RIFKIN (pro hac vice)
M. CELESTE BRUCE (pro hac vice)
RIFKIN, WEINER, LIVINGSTON,
LEVITAN & SILVER, LLC
7979 Old Georgetown Road, Suite 400
Bethesda, MD 20814
Telephone:
[phone]

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SAMUEL KORNHAUSER - #83528
LAW OFFICES OF SAMUEL KORNHAUSER
155 Jackson Street, Suite 1807
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]
BRIAN DAVID, Illinois ARDC No. 0582468
LAW OFFICES OF BRIAN DAVID
33 North LaSalle Street, Suite 3200
Chicago, IL 60610
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiffs

Attorneys for Defendants
Baltimore Orioles Limited Partnership and
Baltimore Orioles, Inc.

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DAVID M. GIVEN - #142375
PHILLIPS, ERLEWINE, GIVEN
& CARLIN LLP
39 Mesa Street, Suite 201
The Presidio
San Francisco, CA 94129
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SERGIO MIRANDA, et al.,

Case No. 3:14-CV-05349-HSG

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Plaintiffs,
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v.

STIPULATION AND ORDER RE
BRIEFING SCHEDULE AND PAGE
LIMITS

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OFFICE OF THE COMMISSIONER OF
BASEBALL, an unincorporated association
doing business as MAJOR LEAGUE
BASEBALL, et al.,

Judge:

Hon. Haywood S. Gilliam, Jr.

Date Filed: December 5, 2014
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Defendants.
Trial Date: None set

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With the exception of Baltimore Orioles Limited Partnership and Baltimore Orioles, Inc.,
Keker & Van Nest is counsel to all Defendants in this matter.

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918992

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STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE AND PAGE LIMITS
Case No. 3:14-CV-05349-HSG

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Plaintiffs and Defendants (collectively, the “Parties”), through their respective
undersigned counsel, hereby stipulate as follows:

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WHEREAS, the Office of the Commissioner of Baseball, Allan Huber “Bud” Selig and

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twenty-nine Major League Baseball Clubs are represented by Keker & Van Nest LLP (“Keker-

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Represented Defendants”), while the Baltimore Orioles, Inc. and Baltimore Orioles, L.P. are

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represented by Rifkin, Weiner, Livingston, Levitan & Silver, LLC (“Orioles Defendants”);

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WHEREAS, pursuant to a Stipulation re Service and Extension of Time to Respond to

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Complaint filed on March 3, 2015, Defendants’ responses to Plaintiffs’ Complaint are due on

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May 14, 2015;

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WHEREAS, Defendants intend to respond to Plaintiffs’ Complaint by filing motions to
dismiss;
WHEREAS, the parties agree that it would be more efficient to file consolidated briefs
where it is practical to do so;
IT IS HEREBY STIPULATED and agreed by and between the Parties that the following
schedule be set:
1. The Keker-Represented Defendants will file a consolidated, joint brief of no more
than 25 total pages in support of their motions to dismiss;
2. The Orioles Defendants will file a consolidated, joint brief in support of their
motions to dismiss;
3. The Plaintiffs will file a consolidated, joint opposition brief of no more than 25

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total pages in response to the Keker-Represented Defendants’ motions to dismiss

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not more than 42 days after the Keker-Represented Defendants file their motions;

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4. The Plaintiffs will file a consolidated, joint opposition brief in response to the

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Orioles Defendants not more than 42 days after the Orioles Defendants file their

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motions;

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5. The Keker-Represented Defendants will file a consolidated, joint reply brief of no

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more than 15 total pages in support of their motions to dismiss not more than 21

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days after Plaintiffs file their opposition brief;

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STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE AND PAGE LIMITS
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6. The Orioles Defendants will file a consolidated, joint reply brief in support of their

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motions to dismiss not more than 21 days after Plaintiffs file their opposition brief;

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7. The Parties will confer regarding a mutually agreeable hearing date prior to the
filing of Defendants’ motions to dismiss.
IT IS SO STIPULATED.

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Dated: March 4, 2015

KEKER & VAN NEST LLP

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By:

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Attorneys for Defendants

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/s/ John W. Keker
JOHN W. KEKER
R. ADAM LAURIDSEN
THOMAS E. GORMAN
DAVID J. ROSEN

Dated: March 4, 2015

RIFKIN, WEINER, LIVINGSTON,
LEVITAN & SILVER, LLC

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By:
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/s/ M. Celeste Bruce
M. CELESTE BRUCE
Attorneys for Defendants
Baltimore Orioles Limited Partnership and
Baltimore Orioles, Inc.

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Dated: March 4, 2015

LAW OFFICES OF SAMUEL
KORNHAUSER

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By:

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/s/ Samuel Kornhauser
SAMUEL KORNHAUSER
Attorneys for Plaintiffs

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STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE AND PAGE LIMITS
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IT IS SO ORDERED.

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Dated: March 10, 2015
The Honorable Haywood S. Gilliam, Jr.
Judge of the Northern District of California

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STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE AND PAGE LIMITS
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CERTIFICATION OF CONCURRENCE FROM OTHER PARTIES

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I, Thomas E. Gorman, am the ECF user whose ID and password are being used to file this
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STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE AND PAGE
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LIMITS. In compliance with N.D. Cal. Civ. L.R. 5-1(i)(3), I hereby attest that each of the
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signatories has concurred in the filing of this document and has authorized the use of his or her
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electronic signature.
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/s/ Thomas E. Gorman
THOMAS E. GORMAN

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STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE AND PAGE LIMITS
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