Bullen v. Citigroup Global Markets, Inc.

Filing 15

STIPULATION AND ORDER Initial Case Management Conference set for 2/3/2010 03:00 PM. VIA TELEPHONE. Signed by Judge ARMSTRONG on 12/8/09. (lrc, COURT STAFF) (Filed on 12/9/2009)

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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 MORGAN, LEWIS & BOCKIUS LLP A T T O R N E Y S A T LAW MORGAN, LEWIS & BOCKIUS LLP GEORGE A. STOHNER (State Bar No. 214508) 300 South Grand Avenue Twenty-Second Floor Los Angeles, CA 90071-3132 Tel: 213.612.2500 Fax: 213.612.2501 gstohner@morganlewis.com MORGAN LEWIS & BOCKIUS LLP DARYL S. LANDY (State Bar No. 136288) MEGAN BARRY BOROVICKA (State Bar No. 241205) One Market, Spear Street Tower San Francisco, CA 94105 Tel: 415.442.1000 Fax: 415.442.1001 dlandy@morganlewis.com mborovicka@morganlewis.com Attorneys for Defendant CITIGROUP GLOBAL MARKETS INC. Robert Byrnes (State Bar No. 200761) Payam Shahian (State Bar No. 228406) PShahian@InitiativeLegal.com Sang Park (State Bar No. 232956) SPark@InitiativeLegal.com Initiative Legal Group APC 1800 Century Park East, 2nd Floor Los Angeles, CA 90067 Telephone: (310) 556-5637 Facsimile: (310)861-9051 Attorneys for Plaintiff Leah Bullen UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION LEAH BULLEN, individually, and on behalf of other members of the general public similarly situated, Plaintiff, vs. CITIGROUP GLOBAL MARKETS, INC., d/b/a SMITH BARNEY, Defendant. DB2/21449015.3 Case No. CV 09 4117 (SBA) STIPULATED REQUEST FOR ORDER CHANGING TIME OF INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES; ORDER 28 1 STIPULATED REQUEST FOR ORDER CHANGING TIME OF INITIAL CASE MANAGEMENT CONFERENCE; PROPOSED ORDER 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 MORGAN, LEWIS & BOCKIUS LLP A T T O R N E Y S A T LAW STIPULATION WHEREAS, the Initial Case Management Conference in the above-captioned case is currently scheduled for December 10, 2009, at 3:00 p.m., via telephone, before the Honorable Saundra B. Armstrong; WHEREAS, lead counsel representing Plaintiff Leah Bullen ("Plaintiff") and Defendant Citigroup Global Markets, Inc. ("Defendant") have been unable to meaningfully meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and the Court's September 4, 2009 Order Setting Initial Case Management Conference and ADR Deadlines; and WHEREAS, as described in the accompanying Declaration of Megan Borovicka, the parties have agreed to stipulate to continue the Initial Case Management Conference due to lead counsels' inability to meet and confer in accordance with the current case schedule, and have begun discussing a discovery time frame and one set of interrogatories has been served; NOW, THEREFORE, pursuant to Civil Local Rule 6-2, Plaintiff and Defendant, through their undersigned respective counsel, stipulate and request that the Court continue the current Initial Case Management Conference date of December 10, 2009, and reschedule the Conference for February 25, 2010 or a later date the Court finds appropriate, and to re-set the related preConference deadlines, including the ADR deadlines, accordingly. 28 DB2/21449015.3 2 Case No. CV 09 4117 (SBA) STIPULATED REQUEST FOR ORDER CHANGING TIME OF INITIAL CASE MANAGEMENT CONFERENCE; PROPOSED ORDER 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 MORGAN, LEWIS & BOCKIUS LLP A T T O R N E Y S A T LAW Dated: _____________________, 2009 MORGAN, LEWIS & BOCKIUS LLP By George A. Stohner Daryl S. Landy Megan Barry Borovicka Attorneys for Defendant CITIGROUP GLOBAL MARKETS INC. Dated: _____________________, 2009 INITIATIVE LEGAL GROUP APC By Robert Byrnes Payam Shahian Sang Park Attorneys for Plaintiff LEAH BULLEN 28 DB2/21449015.3 3 Case No. CV 09 4117 (SBA) STIPULATED REQUEST FOR ORDER CHANGING TIME OF INITIAL CASE MANAGEMENT CONFERENCE; PROPOSED ORDER 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 MORGAN, LEWIS & BOCKIUS LLP A T T O R N E Y S A T LAW ORDER PURSUANT TO THE PARTIES' STIPULATION, IT IS HEREBY ORDERED THAT the Case Management Conference currently scheduled for December 10, 2009, shall be CONTINUED to February 3, 2010, at 3:00 p.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. Plaintiff 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. IT IS FURTHER ORDERED THAT that all related deadlines preceding the Initial Case Management Conference are moved to correspond with the new Conference date. SO ORDERED. Dated: 12/8/09 ________________________________ HON. SAUNDRA B. ARMSTRONG U.S. District Court Judge 28 DB2/21449015.3 4 Case No. CV 09 4117 (SBA) STIPULATED REQUEST FOR ORDER CHANGING TIME OF INITIAL CASE MANAGEMENT CONFERENCE; PROPOSED ORDER

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