Universal Operations Risk Management, LLC et al v. Global Rescue, LLC

Filing 21

STIPULATION AND ORDER, Set/Reset Deadlines as to 11 MOTION to Dismiss , Transfer, or Stay. Responses due by 1/24/2012. Replies due by 1/31/2012.. Signed by Judge ARMSTRONG on 12/27/11. (lrc, COURT STAFF) (Filed on 12/27/2011)

Case4:11-cv-05969-SBA Document20 Filed12/22/11 Page1 of 3

GREENBERG TRAURIG, LLP
1 TODD R. WULFFSON (SBN 150377)
3161 Michelson Drive, Suite 1000
2 Irvine, California 92612
T: [phone]
3 F: [phone]
[e-mail]
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5 VALDEZ SEYEDIN-NOOR DUNSON & DOYLE LLP
AMY K. TODD (SBN 208581)
6 116 New Montgomery Street, Suite 210
San Francisco, CA 94105
7 T: [phone]
F: [phone]
8 [e-mail]
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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12 UNIVERSAL OPERATIONS RISK
MANAGEMENT, LLC, EDWARD
13
MUHLNER, THOMAS BOCHNOWSKI,
14 and MARK COHON,
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Plaintiffs,
v.
GLOBAL RESCUE LLC, and DOES 1
through 10, inclusive,

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Defendants.
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CASE NO. 11-CV-05969 SBA
JOINT STIPULATION AND xxxxxxxxxxx
PROPOSED
ORDER TO EXTEND TIME TO RESPOND TO
DEFENDANT’S NOTICE OF MOTION,
MOTION AND AMENDED MEMORANDUM IN
SUPPORT OF GLOBAL RESCUE LLC’S
MOTION TO DISMISS, TRANSFER, OR STAY
Date: April 10, 2012
Time: 1:00 p.m.
Place: Courtroom 1
Judge: Honorable Saundra B. Armstrong

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JOINT STIPULATION AND PROPOSED ORDER TO EXTEND TIME
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1 TO THE HONORABLE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF
2 RECORD:
WHEREAS, Plaintiffs served their First Amended Complaint in this matter on November 8,

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4 2011;
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WHEREAS, Defendants filed their Notice of Removal in this Court on December 5, 2011;

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WHEREAS, Defendant filed its Motion to Dismiss, Transfer, or Stay before Magistrate Judge

7 Donna M. Ryu on December 12, 2011;
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WHEREAS, this action, Universal Operations Risk Management, LLC et al. v. Global Rescue

9 LLC et al., Case No. 11-CV-05969, was reassigned to the Honorable Saundra B. Armstrong for all
10 further proceedings on December 13, 2011;
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WHEREAS, per the December 13, 2011 Reassignment Order from the Office of the Clerk of

12 Court, Defendant filed its Re-Notice of Motion, Motion and Amended Memorandum in Support of
13 Global rescue LLC’s Motion to Dismiss, Transfer, or Stay (“the Motion”) before the Honorable Saundra
14 B. Armstrong on December 16, 2011;
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WHEREAS, the Court’s first available hearing date is April 10, 2012;

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WHEREAS, there have been no prior requests to extend any deadlines and such a request is

17 made: (1) to remove any arguable requirement for Plaintiffs to respond in a California court in violation
18 of the Temporary Restraining Order issued by the Superior Court of the Commonwealth of
19 Massachusetts, Suffolk, Case No. 11-4502G (and which action has subsequently been removed to and is
20 pending before the U.S. District court for the District of Massachusetts, No. 1:11-civ-12250 (Wolf,
21 C.J.)), which currently prohibits Plaintiffs Muhlner, Bochnowski and Cohon from prosecuting their
22 claims, prosecuting a separate suit, or obtaining relief in any other court except a Massachusetts state or
23 federal court, and specifically prohibits them from prosecuting a separate suit in any state and federal
24 court of California; (2) based on Plaintiffs’ counsel’s request to alleviate any requirement that Plaintiffs’
25 counsel brief and respond to Defendant’s Motion during the upcoming holidays, including during pre26 scheduled holiday vacation time with family, and; (3) for good cause and not for any purposes of delay
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It is therefore agreed to and stipulated by and between the parties and their respective counsel

2 that an extension of deadlines is warranted and the revised schedule shall be as follows:
1.

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Opposition to Defendant’s Re-Notice of Motion re Motion to Dismiss, Transfer or

4 Stay is due January 24, 2012.
2.

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Reply to Plaintiffs’ Opposition to Defendant’s Re-Notice of Motion re Motion to

6 Dismiss, Transfer or Stay is due January 31, 2012.
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Stipulated By and Between:

9 Dated: December 22, 2011

Respectfully submitted,
Valdez Seyedin-Noor Dunson & Doyle LLP

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By: _____/s/ Amy K. Todd____________
Amy K. Todd (SBN 208581)

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Of counsel, Pro Hac Vice Application Pending:
Mark M. Whitney, Mass. BBO #637054
MORGAN, BROWN & JOY, LLP

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15 Dated: December 22, 2011
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Respectfully submitted,
Greenberg Traurig, LLP
By: _____/s/ Todd R. Wulffson__________
Todd R. Wulffson (SBN 150377)

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21 PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
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23 Dated: 12/27/11
The Honorable Saundra B. Armstrong
United States District Judge

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JOINT STIPULATION AND PROPOSED ORDER TO EXTEND TIME
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