Moore et al v. Verizon Communications, Inc. et al

Filing 34

STIPULATION AND ORDER: That the Case Management Conference has been CONTINUED to 12/17/2009 at 03:00 PM., via telephone. Signed by Judge Saundra Brown Armstrong, on 9/18/09. (lrc, COURT STAFF) (Filed on 9/22/2009) Modified on 9/23/2009 (jlm, COURT STAFF).

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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 HENRY WEISSMANN (SBN 132418) MUNGER, TOLLES & OLSON LLP 355 South Grand Avenue Thirty-Fifth Floor Los Angeles, CA 90071-1560 Telephone: (213) 683-9100 Facsimile: (213) 687-3702 E-mail: henry.weissmann@mto.com ROSEMARIE T. RING (SBN 220769) GABRIEL P. SANCHEZ (SBN 241367) MUNGER, TOLLES & OLSON LLP 560 Mission Street Twenty-Seventh Floor San Francisco, CA 94105-2907 Telephone: (415) 512-4000 Facsimile: (415) 512-4077 E-mail: rose.ring@mto.com E-mail: gabriel.sanchez@mto.com Attorneys for Defendants VERIZON COMMUNICATIONS INC., VERIZON CALIFORNIA, INC., VERIZON NORTHWEST, INC., and VERIZON WEST COAST, INC. JEFFREY F. KELLER (SBN 148005) DENISE L. DIAZ (SBN 159516) KELLER GROVER, LLP 425 Second Avenue, Suite 500 San Francisco, CA 94107 Telephone: (415) 543-1305 Facsimile: (415) 543-7861 E-mail: jfkeller@kellergrover.com JOHN G. JACOBS (Admitted Pro Hac Vice) BRYAN G. KOLTON (Admitted Pro Hac Vice) THE JACOBS LAW FIRM CHTD. 122 South Michigan Avenue, Suite 1850 Chicago, IL 60603 Telephone: (312) 427-4000 Facsimile: (312) 427-1850 E-Mail: jgjacobs@thejacobslawfirm.com E-Mail: bgkolton@thejacobslawfirm.com DAVID SCHACHMAN (Admitted Pro Hac Vice) DAVID SCHACHMAN & ASSOCIATES, P.C. 122 South Michigan Avenue, Suite 1850 Chicago, IL 60603 Telephone: (312) 427-9500 Facsimile: (312) 427-1850 E-Mail: ds@schachmanlaw.com Attorneys for Plaintiffs and the Putative Class UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION DESIREE MOORE and KAREN JONES individually and on behalf of a class of similarly situated individuals, Plaintiffs, vs. VERIZON COMMUNICATIONS INC., a Delaware corporation, VERIZON CALIFORNIA, INC., a California corporation, VERIZON NORTHWEST, INC., a Washington corporation, and VERIZON WEST COAST, INC., a California corporation, Defendants. CASE NO. CV 09-1823 SBA STIPULATED REQUEST AND [PROPOSED] ORDER CONTINUING THE INITIAL CASE MANAGEMENT CONFERENCE SCHEDULED FOR OCTOBER 8, 2009 [Declaration of Rosemarie T. Ring In Support of the Stipulated Request and [Proposed] Order Continuing the Initial Case Management Conference Scheduled For October 8, 2009, which is filed concurrently herewith] 8791411.1 STIPULATED REQUEST AND [PROPOSED] ORDER CONTINUING INITIAL CMC CASE NO. CV 09-1823 SBA 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 WHEREAS, the initial case management conference in this case is currently set for October 8, 2009, at 3:30 p.m. WHEREAS, on April 30, 2009, plaintiffs served the Complaint on Defendants. WHEREAS, by stipulation of the parties, Defendants' time to answer or otherwise respond to the Complaint has been extended to August 31, 2009; WHEREAS, prior to August 31, 2009, plaintiffs informed defendants of their intention to file a First Amended Complaint on September 18, 2009, alleging claims and naming parties not at issue in the Complaint; WHEREAS, the parties agreed that Defendants should not respond to the Complaint and that Defendants' deadline to answer or otherwise respond to the First Amended Complaint should be extended to October 19, 2009, and filed a stipulation to that effect on August 21, 2009; WHEREAS, Defendants intend to respond to the First Amended Complaint by filing at least one motion under Rule 12 of the Federal Rules of Civil Procedure that could result in dismissal of the case in its entirety; WHEREAS, given Plaintiffs' intention to file a First Amended Complaint on September 18, 2009, alleging claims and naming parties not at issue in the Complaint, and Defendants' intention to respond to the First Amended Complaint on October 19, 2009, by filing at least one motion under Rule 12 that could result in dismissal of the case in its entirety, the parties have agreed that, subject to the Court's approval, continuance of the initial case management conference until after the Court rules on Defendants' motion or motions to dismiss the First Amended Complaint would allow the parties to comply with their obligations under Rule 26, Civil L.R. 16, and ADR L.R. 3, and the Court to consider the case, in a more informed manner; WHEREAS, defendants reserve their respective rights to raise any and all defenses available to them in answering or otherwise responding to the complaint, including but not limited to challenges to personal jurisdiction and standing, and plaintiffs reserve their rights to seek such discovery as may be necessary to respond to any such challenges; NOW THEREFORE, plaintiffs and defendants through their counsel of record stipulate to the following: 8791411.1 -1- STIPULATED REQUEST AND [PROPOSED] ORDER CONTINUING INITIAL CMC CASE NO. CV 09-1823 SBA 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 By: /s/ John G. Jacobs JOHN G. JACOBS By: /s/ Rosemarie T. Ring ROSEMARIE T. RING DATED: September 16, 2009 MUNGER, TOLLES & OLSON LLP IT IS HEREBY STIPULATED that, subject to the Court's approval, the initial case management conference scheduled for October 8, 2009, at 3:30 p.m., should be continued until after the Court rules on Defendants' motion or motions to dismiss the First Amended Complaint. Attorneys for Defendants VERIZON COMMUNICATIONS INC., VERIZON CALIFORNIA, INC., VERIZON NORTHWEST, INC., and VERIZON WEST COAST, INC. THE JACOBS LAW FIRM, CHTD. Attorneys for Plaintiffs DESIREE MOORE and KAREN JONES 8791411.1 -2- STIPULATED REQUEST AND [PROPOSED] ORDER CONTINUING INITIAL CMC CASE NO. CV 09-1823 SBA 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 SAUNDRA BROWN ARMSTRONG United States District Judge ORDER PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT the Case Management Conference currently scheduled for October 8, 2009, shall be CONTINUED to December 17, 2009, at 3:00p.m. 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 (510) 637-3559 at the above indicated date and time. SO ORDERED. Dated: 9/18/09 8791411.1 -3- STIPULATED REQUEST AND [PROPOSED] ORDER CONTINUING INITIAL CMC CASE NO. CV 09-1823 SBA 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 CERTIFICATION I, Rosemarie T. Ring, am the ECF User whose identification and password are being used to file this STIPULATION AND [PROPOSED] ORDER CONTINUING THE INITIAL CASE MANAGEMENT CONFERENCE SCHEDULED FOR OCTOBER 8, 2009. In compliance with General Order 45.X.B., I hereby attest that John G. Jacobs concurred in this filing. 8791411.1 -4- STIPULATED REQUEST AND [PROPOSED] ORDER CONTINUING INITIAL CMC CASE NO. CV 09-1823 SBA

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