Payne v. Office of the Commissioner of Baseball et al

Filing 34

STIPULATION AND MODIFIED ORDER For Administrative Relief From Initial Case Management Schedule. Case Management Statement due by 12/30/2015. Initial Case Management Conference set for 1/8/2016 10:00 AM in Courtroom 1, 17th Floor, San Francisco. Signed by Judge Samuel Conti on 09/24/2015. (tmiS, COURT STAFF) (Filed on 9/24/2015)

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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]
PHILIP J. TASSIN - #287787
[e-mail]
633 Battery Street
San Francisco, CA 94111-1809
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
OFFICE OF THE COMMISSIONER OF
BASEBALL (d/b/a MAJOR LEAGUE
BASEBALL); and ROBERT D. MANFRED,
JR.

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HAGENS BERMAN SOBOL SHAPIRO
LLP
STEVE W. BERMAN (Pro Hac Vice)
[e-mail]
ANTHEA GRIVAS (Pro Hac Vice)
[e-mail]
1918 Eighth Avenue, Suite 3300
Seattle, WA 98101
Telephone:
[phone]
Facsimile:
[phone]
HILLIARD MUÑOZ GONZALES L.L.P.
ROBERT C. HILLIARD (Pro Hac Vice)
[e-mail]
MARION REILLY (Pro Hac Vice)
[e-mail]
719 S Shoreline Boulevard, Suite 500
Corpus Christi, TX 78401
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff
GAIL PAYNE

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[Additional counsel listed on signature page]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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GAIL PAYNE, individually and on behalf
of all others similarly situated,

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Plaintiff,
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v.
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OFFICE OF THE COMMISSIONER OF
BASEBALL (d/b/a MAJOR LEAGUE
BASEBALL); and ROBERT D.
MANFRED, JR.,

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Case No. 3:15-cv-03229-SC
JOINT STIPULATION AND [PROPOSED]
ORDER FOR ADMINISTRATIVE
RELIEF FROM INITIAL CASE
MANAGEMENT SCHEDULE

Defendants.

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Judge:

Hon. Samuel Conti

Date Filed: July 13, 2015

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JOINT STIPULATION AND [PROPOSED] ORDER FOR
ADMINISTRATIVE RELIEF FROM INITIAL CASE MANAGEMENT SCHEDULE
Case No. 3:15-cv-03229-SC
986557

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Plaintiff Gail Payne and Defendants Office of the Commissioner of Baseball (d/b/a/ Major

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League Baseball) and Robert. D. Manfred, Jr., by and through their undersigned counsel, stipulate

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and agree as follows:

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WHEREAS, on October 2, 2015, the Defendants will move to dismiss Plaintiff’s

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Complaint because Defendants assert that Plaintiff lacks standing and has failed to state a claim

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for relief;

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WHEREAS, Plaintiff’s opposition brief will be due October 16, 2015, Defendants’ reply

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brief will be due October 23, 2015, and the first possible date when the Court could hear

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argument on the motion to dismiss will be in November 2015;

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WHEREAS, under N.D. Cal. L.R. 16-2(a), the Initial Case Management Conference was
scheduled—by default—for October 23, 2015;

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WHEREAS, the parties believe that it would be needlessly inefficient to hold an Initial

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Case Management Conference before the Court has an opportunity to consider the motion to

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dismiss;

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WHEREAS, the parties believe that the most efficient case management schedule is to

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hold an Initial Case Management Conference 30 days after the Court issues a final determination

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on any motion to dismiss (and that all related deadlines be reset based on that Case Management

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Conference date);

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IT IS THEREFORE HEREBY STIPULATED that:

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1. The Initial Case Management Conference currently scheduled for October 23, 2015

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(Dkt. 31) and all related deadlines shall be continued;

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2. The Court shall re-schedule the Initial Case Management Conference upon final

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determination of any motion to dismiss.

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JOINT STIPULATION AND [PROPOSED] ORDER FOR
ADMINISTRATIVE RELIEF FROM INITIAL CASE MANAGEMENT SCHEDULE
Case No. 3:15-cv-03229-SC
986557

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SO STIPULATED AND AGREED

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Dated: September 24, 2015

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KEKER & VAN NEST LLP

By:

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Attorneys for Defendants
OFFICE OF THE COMMISSIONER OF
BASEBALL (d/b/a MAJOR LEAGUE
BASEBALL); and ROBERT D.
MANFRED, JR.

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/s/ John W. Keker
JOHN W. KEKER
R. ADAM LAURIDSEN
THOMAS E. GORMAN
PHILIP J. TASSIN

Dated: September 24, 2015

HAGENS BERMAN SOBOL SHAPIRO
LLP

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By:

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Attorneys for Plaintiff
GAIL PAYNE

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/s/ Steve W. Berman
STEVE W. BERMAN
ANTHEA GRIVAS
JEFF D. FRIEDMAN
JON T. KING

Dated: September 24, 2015

HILLIARD MUÑOZ GONZALES L.L.P.

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By:

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/s/ Robert Hilliard
ROBERT HILLIARD
MARION M. REILLY
Attorneys for Plaintiff
GAIL PAYNE

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PURSUANT TO STIPULATION, IT IS SO ORDERED: The case management
conference is continued to Friday, 01/08/2016, at 10:00 AM.

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Dated:

09/24 , 2015
Hon. Samuel Conti
United States Senior District Court Judge

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JOINT STIPULATION AND [PROPOSED] ORDER FOR
ADMINISTRATIVE RELIEF FROM INITIAL CASE MANAGEMENT SCHEDULE
Case No. 3:15-cv-03229-SC
986557