Guerrero v. Mobile Funster, Inc. et al

Filing 14

STIPULATION AND ORDER Initial Case Management Conference set for 3/25/2009 03:00 PM. VIA TELEPHONE. Signed by Judge ARMSTRONG on 11/10/08. (lrc, COURT STAFF) (Filed on 11/12/2008)

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Sarah Wager (State Bar No. 209277) [e-mail] DECHERT LLP 2440 W. El Camino Real, Suite 700 Mountain View, CA 94040-1499 Telephone: [phone] Facsimile: 650.813.4848 Michael S. Doluisio (Admitted Pro Hac Vice) [e-mail] Karen C. Daly (Admitted Pro Hac Vice) [e-mail] DECHERT LLP Cira Center, 2929 Arch Street Philadelphia, PA 19104 Telephone: [phone] Facsimile: 215.994.2222 Attorneys for Defendants MOBILEFUNSTER, INC. and FUNMOBILE GAMES, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

WENDI GUERRERO, individually and on behalf of a class similarly situated individuals, Plaintiff, v. MOBILE FUNSTER, INC., a Delaware corporation, FUNMOBILE GAMES, INC., a Delaware corporation, Defendants.

Case No. 4:08-CV-4389 SBA STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

WHEREAS on September 18, 2008 defendants Mobilefunster, Inc. and Funmobile Games, Inc. ("Defendants") filed a Notice of Removal with this Court; WHEREAS on September 18, 2008 the Court issued an Order Setting Initial Case Management Conference and ADR Deadlines, which set the Initial Case Management Conference for January 7, 2009 at 3:00 p.m., and related case management deadlines flowing from that date
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO: 4:08-CV-4389 SBA 13304548.1

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(Document No. 2); WHEREAS Plaintiff filed a Motion to Remand, which will be opposed by Defendants, and is set for hearing on December 16, 2008 (Document 5); WHEREAS the parties believe that the issues to be discussed at the Case Management Conference and the related case management deadlines may become moot if the Court grant's Plaintiff's Motion to Remand; WHEREAS on September 18, 2008 Plaintiff and Defendants stipulated that Defendants shall have an extension of time to answer, move or otherwise plead in response to the First Amended Class Action Complaint until thirty (30) days after Plaintiffs' motion to remand is finally ruled upon (Document No. 3); NOW, THEREFORE, based on the foregoing, the parties do hereby stipulate, by and through their counsel of record, to move the Case Management Conference from January 21, 2009 to March 25, 2009 at 3:00 p.m., that all related case management deadlines be reset in accordance therewith, and respectfully request that the Court issue an order reflecting same. The parties shall meet and confer prior to the conference and shall prepare a joint Case Management Conference Statement which shall be filed no later than ten (10) days prior to the Case Management Conference that complies with the Standing Order For All Judges Of The Northern District Of California and the Standing Order of this Court. Plaintiffs shall be responsible for filing the statement as well as for arranging the conference call. All parties shall be on the line and shall call [phone] at the above indicated date and time. Dated: November 5, 2008 DECHERT LLP By:/s/ Sarah Wager Sarah Wager Attorneys for Defendants MOBILEFUNSTER, INC. and FUNMOBILE GAMES, INC. Michael S. Doluisio (Admitted Pro Hac Vice) [e-mail] Karen C. Daly (Admitted Pro Hac Vice) [e-mail] DECHERT LLP Cira Center, 2929 Arch Street
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO: 4:08-CV-4389 SBA 13304548.1

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS SO ORDERED Dated: 11/10/08 Dated: November 5, 2008

Philadelphia, PA 19104 Telephone: [phone] Facsimile: 215.994.2222 KAMBEREDELSON, LLC By:/s/ Alan Himmelfarb Alan Himmelfarb Attorneys for Plaintiff WENDI GUERRERO, individually and on behalf of a class of similarly situated individuals GENERAL ORDER 45 ATTESTATION I, Sarah Wager, am the ECF user whose ID and password are being used to file this Stipulation to Continue Case Management Conference. In compliance with General Order 45, I hereby attest that Alan Himmelfarb of Kamberedelson, LLC have concurred in this filing. Dated: November 5, 2008 DECHERT LLP By:/s/ Sarah Wager Sarah Wager Attorneys for Defendants MOBILEFUNSTER, INC. and FUNMOBILE GAMES, INC.

UNITED STATES DISTRICT COURT JUDGE

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO: 4:08-CV-4389 SBA 13304548.1

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