Forouhar v. Statoil, ASA

Filing 73

STIPULATION AND ORDER, Motions terminated: 66 MOTION for Leave to File Response to Plaintiff's Objections to Reply Declarations filed by Statoil, ASA.. Signed by Judge ARMSTRONG on 3/15/11. (lrc, COURT STAFF) (Filed on 3/16/2011)

Forouhar v. Statoil, ASA

Doc. 73

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SULLIVAN & CROMWELL LLP

Brendan P. Cullen (SBN 194057) ([e-mail]) Laura Kabler Oswell (SBN 241281) ([e-mail]) Achyut J. Phadke (SBN 261567) ([e-mail]) SULLIVAN & CROMWELL LLP 1870 Embarcadero Road Palo Alto, California 94303 Telephone: [phone] Facsimile: [phone] Attorneys for Specially Appearing Defendant Statoil ASA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 10-3623 (SBA)

MITRA N. FOROUHAR, Plaintiff, v. STATOIL ASA, Defendant.

JOINT STIPULATION AND ORDER CONCERNING STATOIL ASA'S ADMINISTRATIVE MOTION [SPECIALLY APPEARING DEFENDANT STATOIL ASA'S ADMINISTRATIVE MOTION AND DECLARATION OF LAURA KABLER OSWELL FILED CONCURRENTLY HEREWITH] Judge: The Hon. Saundra B. Armstrong Courtroom: 1

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING ADMINISTRATIVE MOTION CASE NO. 10-3623 (SBA) Dockets.Justia.com

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WHEREAS, on February 22, 2011, Plaintiff Mitra N. Forouhar filed Plaintiff's Objections to Defendant Statoil's Reply Declarations (Dkt. 62) ("Objections") and the Supplemental Declaration of Jon F. Claudi in Support of Plaintiff's Opposition to Defendant's Motion to Dismiss and Plaintiff's Objections to Defendant's Reply Declarations (Dkt. 64) ("Supplemental Claudi Declaration")

5 in connection with briefing on Specially Appearing Defendant Statoil ASA's ("Statoil's") Motion to 6 Dismiss the Complaint (Dkt. 16); 7 WHEREAS, on March 9, 2011, Statoil filed an Administrative Motion Requesting Leave

8 to File its Response to Plaintiff's Objections to Reply Declarations ("Administrative Motion") pursuant 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
SULLIVAN & CROMWELL LLP

to Local Rule 7-11 that requested the Court to permit Statoil to file a response to the Objections and Supplemental Claudi Declaration, and filed a copy of its Response to Plaintiff's Objections to Reply Declarations ("Response") as Exhibit A to the Declaration of Laura Kabler Oswell; WHEREAS, without waiving any rights with respect to the Objections or the Supplemental Claudi Declaration, Plaintiff Mitra Forouhar does not oppose Statoil's Administrative Motion; WHEREAS Plaintiff Mitra Forouhar contends that she should be allowed to file the Supplemental Claudi Declaration in response to matters raised in Statoil's reply papers and intends to file an administrative motion requesting leave to file the Supplemental Claudi Declaration; WHEREAS, having already addressed the propriety of the filing of the Supplemental Claudi Declaration in its Response, Statoil does not intend to file any further opposition to the filing of the Supplemental Claudi Declaration; NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the parties, through their undersigned counsel, as follows: 1. Statoil may file its Response.

IT IS SO STIPULATED.

-1JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING ADMINISTRATIVE MOTION CASE NO. 10-3623 (SBA)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Joint Stipulation and [Proposed] Order Concerning Statoil ASA's Administrative Motion. In 19 compliance with General Order No. 45, X.B., I hereby attest that Michael D. Seplow has concurred in 20 this filing. 21 22 23 24 25 26 27 28
SULLIVAN & CROMWELL LLP

DATED: March 9, 2011

SCHONBRUN DESIMONE SEPLOW HARRIS HOFFMAN & HARRISON, LLP PAUL L. HOFFMAN MICHAEL D. SEPLOW /s/ Michael D. Seplow Michael D. Seplow 723 Ocean Front Walk Venice, California 90291 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff

DATED: March 9, 2011

SULLIVAN & CROMWELL LLP BRENDAN P. CULLEN LAURA KABLER OSWELL ACHYUT J. PHADKE /s/ Brendan P. Cullen Brendan P. Cullen 1870 Embarcadero Road Palo Alto, California 94303 Telephone: [phone] Facsimile: [phone] Attorneys for Specially Appearing Defendant Statoil ASA

I, Brendan P. Cullen, am the ECF user whose ID and password are being used to file this

/s/Brendan P. Cullen Brendan P. Cullen

-2JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING ADMINISTRATIVE MOTION CASE NO. 10-3623 (SBA)

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SULLIVAN & CROMWELL LLP

ORDER

THE FOREGOING STIPULATION IS APPROVED. NOW, THEREFORE, IT IS ORDERED, ADJUDGED, AND DECREED: 1. 2. Statoil's Administrative Motion is GRANTED; Statoil's Response is FILED with the Court.

IT IS SO ORDERED.

Dated: _3/15/11________________________ THE HONORABLE SAUNDRA B. ARMSTRONG UNITED STATES DISTRICT JUDGE

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING ADMINISTRATIVE MOTION CASE NO. 10-3623 (SBA)