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

Filing 45

Order by Hon. Haywood S Gilliam, Jr granting 44 Stipulation. (hsglc3, COURT STAFF) (Filed on 6/25/2015)

1
2

8

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:
415 391 5400
Facsimile:
415 397 7188

9

Attorneys for Defendants

3
4
5
6
7

10
11
12
13
14
15

1

SAMUEL KORNHAUSER - #83528
LAW OFFICES OF SAMUEL KORNHAUSER
155 Jackson Street, Suite 1807
San Francisco, CA 94111
Telephone:
415 981 6281
Facsimile:
415 981 7616
BRIAN DAVID, Illinois ARDC No. 0582468
LAW OFFICES OF BRIAN DAVID
33 North LaSalle Street, Suite 3200
Chicago, IL 60610
Telephone:
847 778 7528
Facsimile:
312 346 8469
Attorneys for Plaintiffs

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:
301 951 0150

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]

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

16
17

UNITED STATES DISTRICT COURT

18

NORTHERN DISTRICT OF CALIFORNIA

19
SERGIO MIRANDA, et al.,

SAN FRANCISCO DIVISION
Case No. 3:14-cv-05349-HSG

20
Plaintiffs,
21

STIPULATION AND [PROPOSED]
ORDER FOR CHANGING TIME

v.
22
23
24

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

25

Hon. Haywood S. Gilliam, Jr.

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

Defendants.

26
27
28

1

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

STIPULATION AND [PROPOSED] ORDER FOR CHANGING TIME
Case No. 3:14-CV-05349-HSG

1

Pursuant to Local Civil Rules 6-1 and 6-2, the parties through undersigned counsel hereby

2

stipulate and respectfully request that the Court extend the deadline for Plaintiffs’ Opposition to

3

Defendants’ Motion to Dismiss. The parties declare in support of this request:

4

WHEREAS, pursuant to a Stipulation Changing Time, filed on March 4, 2015, the parties

5

stipulated to moving a scheduled case management conference from March 10, 2015 to March 17,

6

2015, due to a scheduling conflict for Plaintiffs’ counsel;

7

WHEREAS, pursuant to the Stipulation and Order re Briefing Schedule and Page Limits,

8

issued on March 10, 2015, Plaintiffs’ opposition to Defendants’ motion to dismiss is due on June 25,

9

2015, and the Defendants’ reply to the Plaintiffs’ opposition is due on July 16, 2015;

10
11

WHEREAS, Plaintiffs request a five-day extension of time for filing the opposition to the
motion to dismiss, due to a scheduling conflict for Plaintiffs’ counsel;

12

WHEREAS, Defendants do not oppose the request;

13

WHEREAS, Plaintiffs agree to extend the deadline of Defendants’ reply to Plaintiffs’

14
15
16

opposition by five days;
THEREFORE, pursuant to Local Rule 6-2, the parties through their respective attorneys
stipulate as follows:

17

1. Plaintiffs shall file their Opposition to the Motion to Dismiss on June 30, 2015;

18

2. Defendants shall file their Reply to the Opposition on July 21, 2015.

19

IT IS SO STIPULATED AND AGREED

20
21

Dated: June 24, 2015

KEKER & VAN NEST LLP

22

25

/s/ R. Adam Lauridsen
JOHN W. KEKER
R. ADAM LAURIDSEN
THOMAS E. GORMAN
DAVID J. ROSEN

26

Attorneys for Defendants

23
24

By:

27
28
1
STIPULATION AND [PROPOSED] ORDER FOR CHANGING TIME
Case No. 3:14-CV-05349-HSG

RIFKIN, WEINER, LIVINGSTON,
LEVITAN AND SILVER, LLC

1
2
3

By:

4
5

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

6
7
8
9

/s/ M. Celeste Bruce
ALAN MARK RIFKIN (pro hac vice)
MARIE CELESTE BRUCE (pro hac vice)

Dated: June 24, 2015

By:

LAW OFFICES OF SAMUEL
KORNHAUSER

10

/s/ Samuel Kornhauser
SAMUEL KORNHAUSER

11

Attorneys for Plaintiffs

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
STIPULATION AND [PROPOSED] ORDER FOR CHANGING TIME
Case No. 3:14-CV-05349-HSG
957412

1

CERTIFICATION OF CONCURRENCE FROM OTHER PARTIES

2

I, David J. Rosen, am the ECF user whose ID and password are being used to file this

3

STIPULATION AND [PROPOSED] ORDER FOR CHANGING TIME. In compliance with N.D.

4

Cal. Civ. L.R. 5-1(i)(3), I hereby attest that each of the signatories has concurred in the filing of this

5

document and has authorized the use of his or her electronic signature.

6
7

/s/ David J. Rosen
DAVID J. ROSEN

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
STIPULATION AND [PROPOSED] ORDER FOR CHANGING TIME
Case No. 3:14-CV-05349-HSG
957412

1
2

IT IS SO ORDERED.

3
4
Dated:
5
6

June 25, 2015
Hon. Haywood S. Gilliam, Jr.
Judge of the Northern District of California

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4
STIPULATION AND [PROPOSED] ORDER FOR CHANGING TIME
Case No. 3:14-CV-05349-HSG
957412