Payne v. Office of the Commissioner of Baseball et al

Filing 40

STIPULATION AND ORDER Regarding Deadline to File Response In Opposition to Defendants' Motion to Dismiss. Responses due by 10/23/2015. Signed by Judge Samuel Conti on 10/16/2015. (tmiS, COURT STAFF) (Filed on 10/16/2015)

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ROBERT C. HILLIARD (Pro Hac Vice)
MARION REILLY (Pro Hac Vice)
HILLIARD MUÑOZ GONZALES L.L.P.
719 S Shoreline Blvd., Suite #500
Corpus Christi, TX 78401
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Steve W. Berman (Pro Hac Vice)
Anthea Grivas (Pro Hac Vice)
HAGENS BERMAN SOBOL SHAPIRO LLP
1918 Eighth Avenue, Suite 3300
Seattle, WA 98101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

KEKER & VAN NEST LLP
JOHN W. KEKER - #49092
R. ADAM LAURIDSEN - #243780
THOMAS E. GORMAN - #279409
PHILIP J. TASSIN - #287787
633 Battery Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
OFFICE OF THE COMMISSIONER OF
BASEBALL (d/b/a MAJOR LEAGUE
BASEBALL); and ROBERT D. MANFRED,
JR.

Attorneys for Plaintiff
GAIL PAYNE

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[Additional Counsel on Signature Page]

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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

No. 3:15-cv-03229-SC

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Plaintiff,

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

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JOINT STIPULATION AND PROPOSED ORDER
C.A. NO. 3:15-CV-03229-SC

JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING
DEADLINE TO FILE RESPONSE IN
OPPOSITION TO DEFENDANTS’
MOTION TO DISMISS
Judge: Hon. Samuel Conti
Date Filed: October 15, 2015

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

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

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dispute and agree as follows:

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WHEREAS, on July 13, 2015, Plaintiff filed her Original Complaint;

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WHEREAS, on October 2, 2015, Defendants filed a Motion to Dismiss the Original

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Complaint pursuant to Federal Rule of Civil Procedure 12(b);
WHEREAS, Plaintiff’s deadline to file her Response in Opposition to Defendants' Motion
to Dismiss is currently October 16, 2015;
WHEREAS, Plaintiff's deadline to file an Amended Complaint as a matter of right is
October 23, 2015;
WHEREAS, Defendants have agreed to withdraw their Motion to Dismiss the Original
Complaint if Plaintiff files an Amended Complaint by October 23, 2015;
WHEREAS, the parties believe that it would be inefficient to require Plaintiff to file her
Response in Opposition before her deadline to file an Amended Complaint;

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IT IS THEREFORE STIPULATED that:

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1. Plaintiff's Response to Defendants’ Motion to Dismiss shall be continued from October

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16, 2015 to October 23, 2015.

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SO STIPULATED AND AGREED:

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JOINT STIPULATION AND PROPOSED ORDER
C.A. NO. 3:15-CV-03229-SC

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DATED: October 15, 2015

HILLIARD MUÑOZ GONZALES L.L.P.

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By

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

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DATED: October 15, 2015

By

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/s/ Steve W. Berman
STEVE W. BERMAN
ANTHEA GRIVAS
Attorneys for Plaintiff
GAIL PAYNE

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DATED: October 15, 2015

By

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/s/ John W. Keker
JOHN W. KEKER
R. ADAM LAURIDSEN
THOMAS E. GORMAN
PHILIP J. TASSIN
Attorneys for Defendants
OFFICE OF THE COMMISSIONER OF
BASEBALL (d/b/a MAJOR LEAGUE
BASEBALL); and ROBERT D.
MANFRED, JR.

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PURSUANT TO A STIPULATION BETWEEN THE PARTIES, IT IS SO ORDERED:

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Plaintiff's deadline to file her Response in Opposition to Defendants' Motion to Dismiss is

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continued to October 23, 2015.

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10/16/2015
Dated: ______________

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_________________________________
United States District Court Judge

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JOINT STIPULATION AND PROPOSED ORDER
C.A. NO. 3:15-CV-03229-SC

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