Klausner v. Lucas Film Entertainment Company LTD et al

Filing 53

ORDER re 52 Granting Stipulation To File Corrected Declaration Of Stacy North. Signed by Judge Claudia Wilken on 9/9/2010. (ndr, COURT STAFF) (Filed on 9/9/2010)

Klausner v. Lucas Film Entertainment Company LTD et al

Doc. 53

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2200 Geng Road, Suite 230, Palo Alto, CA 94303 PHONE [phone] · FAX [phone]

Andrew F. Pierce, Esq. (State Bar No. 101889) Stacy North, Esq. (State Bar No. 219034) PIERCE & SHEARER LLP 2200 Geng Road, Suite 230 Palo Alto, CA 94303 Phone [phone] Fax [phone] E-Mail: [e-mail] [e-mail] Attorneys for Plaintiff DREW KLAUSNER ROBERT M. LIEBER, ESQ. SBN: 039976 NAKI M. IRVIN, ESQ. SBN: 094120 MARGOLIS & TISMAN LLP 601 Montgomery Street, Suite 2030 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] Attorneys for Defendant INDUSTRIAL LIGHT AND MAGIC, a division of LUCASFILM ENTERTAINMENT COMPANY LTD.

PIERCE & SHEARER LLP

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 vs. LUCAS FILM ENTERTAINMENT COMPANY LTD, a California corporation; INDUSTRIAL LIGHT & MAGIC, a California corporation; and DOES 1-25, inclusive, Defendants. ____________________________________ DREW KLAUSNER, an individual, Plaintiff STIPULATION FOR ODER TO FILE CORRECTED DECLARATION OF STACY NORTH IN SUPPORT OF OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION Case No. C 09-03502 CW

1 Case No. C 09-03502 CW STIPULATION FOR ORDER TO FILE CORRECTED DECLARATION OF STACY NORTH IN SUPPORT OF DEFENDANT'S MOTION FOR SUMMARY JUDGMENT Dockets.Justia.com

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2200 Geng Road, Suite 230, Palo Alto, CA 94303 PHONE [phone] · FAX [phone]

STIPULATION OF THE PARTIES WHEREAS, on August 26, 2010, Plaintiff filed the Declaration of Stacy North in Support of Opposition to Defendant's Motion for Summary Judgment or, Alternatively, Summary Adjudication, Docket No. 48 ("North Declaration"); WHEREAS, excerpts from the Deposition of Michael Van Eps ("Van Eps Deposition") were attached to the North Declaration as Exhibit 2, including several exhibits that Defendant designated as Confidential or Attorneys' Eyes Only (the "Confidential Exhibits") under the Protective Order that the Court entered on March 22, 2010 (Docket # 29); WHEREAS, Plaintiff does not agree with the appropriateness of the "Confidential" and "Attorneys Eyes Only" designations on the Confidential Exhibits; WHEREAS, Defendant asserts that the Confidential Exhibits are appropriately designated because they include private employment information, including performance rankings, of nonparties; WHEREAS, the Confidential Exhibits contain, among other things, the names of Defendant's employees; WHEREAS, Defendant has requested, and Plaintiff is agreeable, to removing the North Declaration from the docket, redacting the employees' names from the Confidential Exhibits, and filing a Corrected North Declaration with redacted versions of the Confidential Exhibits; WHEREAS, filing a Corrected North Declaration will not delay the summary judgment hearing, which is scheduled for September 16, 2010, or otherwise affect the schedule for this case. THEREFORE, the Parties to this action, by and through their counsel of record, hereby stipulate and request the Court to order that the North Declaration, Docket No. 48, be withdrawn from the docket, and that Plaintiff be permitted to file a Corrected North Declaration (only with respect to redacting the employees' names from the Confidential Exhibits). // // // //
2 Case No. C 09-03502 CW STIPULATION FOR ORDER TO FILE CORRECTED DECLARATION OF STACY NORTH IN SUPPORT OF DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

PIERCE & SHEARER LLP

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2200 Geng Road, Suite 230, Palo Alto, CA 94303 PHONE [phone] · FAX [phone]

IT IS SO STIPULATED.

DATED: ______________, 2010

PIERCE & SHEARER LLP By: __________________ STACY Y. NORTH Attorneys for Plaintiff DREW KLAUSNER

DATED: ______________, 2010

MARGOLIS & TISMAN LLP By: __________________ ROBERT M. LIEBER Attorneys for Defendant INDUSTRIAL LIGHT AND MAGIC, a division of LUCASFILM ENTERTAINMENT COMPANY LTD.

PIERCE & SHEARER LLP

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: 9/9/2010

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED.

__________________________________ HON. CLAUDIA WILKEN United States District Court Judge

3 Case No. C 09-03502 CW STIPULATION FOR ORDER TO FILE CORRECTED DECLARATION OF STACY NORTH IN SUPPORT OF DEFENDANT'S MOTION FOR SUMMARY JUDGMENT