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

Filing 49

STIPULATION AND ORDER Initial Case Management Conference set for 2/2/2010 01:00 PM.. Signed by Judge ARMSTRONG on 12/8/09. (lrc, COURT STAFF) (Filed on 12/9/2009)

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HENRY WEISSMANN (SBN 132418) MUNGER, TOLLES & OLSON LLP 355 South Grand Avenue Thirty-Fifth Floor Los Angeles, CA 90071-1560 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Defendants VERIZON COMMUNICATIONS INC., VERIZON CALIFORNIA INC., VERIZON NORTHWEST INC., VERIZON WEST COAST INC., VERIZON CORPORATE SERVICES GROUP INC., VERIZON SERVICES CORP., TELESECTOR RESOURCES GROUP, INC. d/b/a VERIZON SERVICES GROUP, VERIZON SERVICES OPERATIONS INC., VERIZON SERVICES ORGANIZATION, INC., VERIZON CORPORATE SERVICES CORP., and VERIZON DATA SERVICES, INC. [Additional Counsel on Signature Page]

JEFFREY F. KELLER (SBN 148005) DENISE L. DIAZ (SBN 159516) KELLER GROVER, LLP 425 Second Avenue, Suite 500 San Francisco, CA 94107 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Plaintiffs and the Putative Class [Additional Counsel on Signature Page]

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., VERIZON CALIFORNIA, INC., VERIZON NORTHWEST, INC., VERIZON WEST COAST, INC., VERIZON CORPORATE SERVICES GROUP INC., VERIZON SERVICES CORP., TELESECTOR RESOURCES GROUP, INC. d/b/a VERIZON SERVICES GROUP, VERIZON SERVICES OPERATIONS INC., VERIZON SERVICES ORGANIZATION, INC., VERIZON CORPORATE SERVICES CORP., VERIZON DATA SERVICES, INC., and DOES 1 through 25 Defendants. CASE NO. CV 09-1823 SBA STIPULATED REQUEST AND ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE SCHEDULED FOR DECEMBER 17, 2009

STIPULATED REQUEST AND [PROPOSED] ORDER TO CONTINUE 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, on September 16, 2009, the parties filed a stipulated request to continue the initial case management scheduled for October 8, 2009, given Plaintiffs' intention to file a First Amended Complaint and Defendants' intention to file a motion to dismiss under Rule 12 of the Federal Rules of Civil Procedure that could result in dismissal of the action in its entirety; WHEREAS, on September 18, 2009, plaintiffs filed their First Amended Complaint; WHEREAS, by order dated September 18, 2009, the Court continued the October 8, 2009, initial case management conference to December 17, 2009, at 3:00 p.m.; WHEREAS, on October 19, 2009, the parties filed a stipulation extending Defendants' time to respond to the First Amended Complaint and setting the following briefing schedule for Defendant's Motion to Dismiss the First Amended Complaint: · · · Motion due: November 2, 2009 Opposition to Motion due: December 7, 2009 Reply in support of Motion due: January 15, 2009

WHEREAS, the hearing on Defendants' Motion is scheduled for February 2, 2010, at 1:00 p.m.; WHEREAS, given that Defendants' Motion could result in dismissal of the action in its entirety, and that briefing and argument on the motion will not be completed until February 2, 2010, 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 would allow the parties to comply with their obligations under Rule 26, Civil L.R. 16, and ADR L.R. 3, and allow the Court to consider the case in a more informed manner; NOW THEREFORE, plaintiffs and defendants through their counsel of record stipulate to the following: IT IS HEREBY STIPULATED that, subject to the Court's approval, the initial case management conference scheduled for December 17, 2009, at 3:00 p.m., should be continued until after the Court rules on Defendants' Motion To Dismiss the First Amended Complaint.

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STIPULATED REQUEST AND [PROPOSED] ORDER TO CONTINUE 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/ ROSEMARIE T. RING DATED: December 1, 2009 MUNGER, TOLLES & OLSON LLP

Attorneys for Defendants VERIZON COMMUNICATIONS INC., VERIZON CALIFORNIA INC., VERIZON NORTHWEST INC., VERIZON WEST COAST INC., VERIZON CORPORATE SERVICES GROUP INC., VERIZON SERVICES CORP., TELESECTOR RESOURCES GROUP, INC. d/b/a VERIZON SERVICES GROUP, VERIZON SERVICES OPERATIONS INC., VERIZON SERVICES ORGANIZATION, INC., VERIZON CORPORATE SERVICES CORP., and VERIZON DATA SERVICES, INC. THE JACOBS LAW FIRM, CHTD.

By:

/s/ JOHN G. JACOBS

Attorneys for Plaintiffs DESIREE MOORE and KAREN JONES

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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 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: [phone] Facsimile: [phone] E-mail: [e-mail] E-mail: [e-mail] 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: [phone] Facsimile: [phone] E-Mail: [e-mail] E-Mail: [e-mail]

Attorneys for Defendants DAVID SCHACHMAN (Admitted Pro Hac VERIZON COMMUNICATIONS INC., Vice) VERIZON CALIFORNIA INC., VERIZON DAVID SCHACHMAN & ASSOCIATES, NORTHWEST INC., VERIZON WEST P.C. COAST INC., VERIZON CORPORATE 122 South Michigan Avenue, Suite 1850 SERVICES GROUP INC., VERIZON Chicago, IL 60603 SERVICES CORP., TELESECTOR Telephone: [phone] RESOURCES GROUP, INC. d/b/a Facsimile: [phone] VERIZON SERVICES GROUP, VERIZON E-Mail: [e-mail] SERVICES OPERATIONS INC., VERIZON SERVICES ORGANIZATION, Attorneys for Plaintiffs and the Putative Class INC., VERIZON CORPORATE SERVICES CORP., and VERIZON DATA SERVICES, INC.

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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 Dated: 12/8/09 PURSUANT TO THE PARTIES' STIPULATION, IT IS HEREBY ORDERED THAT the Case Management Conference currently scheduled for December 17, 2009, shall be CONTINUED to February 2, 2010, at 1:00 p.m., to follow the hearing on Defendant's Motion to Dismiss the First Amended Complaint currently scheduled on that date and time. 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. SO ORDERED. ORDER

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CASE NO. CV 09-1823 SBA