Securities And Exchange Commission v. Schroeder

Filing 54

STIPULATION AND ORDER shortening time on KLA-Tencor Corporation's MOtion for Protective Order. Defendant's opposition due 2/11/2008 by noon. Motion hearing set for 2/12/2008, 10:00 AM in Courtroom 2. Signed by Magistrate Judge Howard R. Lloyd on 2/8/2008. (hrllc2, COURT STAFF) (Filed on 2/8/2008)

Securities And Exchange Commission v. Schroeder

Doc. 54

Case 5:07-cv-03798-JW

Document 54

Filed 02/08/2008

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MORGAN, LEWIS & BOCKIUS LLP
A T T O R N E Y S A T LAW S A N FR A N C I S C O

MORGAN, LEWIS & BOCKIUS LLP JOHN H. HEMANN, State Bar No. 165823 JOSEPH E. FLOREN, State Bar No. 168292 THOMAS R. GREEN, State Bar No. 203980 One Market, Spear Street Tower San Francisco, CA 94105-1126 Tel: [phone] Fax: [phone] E-mail: [e-mail] [e-mail] [e-mail] Attorneys for Non-Party KLA-TENCOR CORPORATION

*ORDER E-FILED 2/8/2008*

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION **MODIFIED BY THE COURT** SECURITIES AND EXCHANGE COMMISSION, Plaintiff, vs. KENNETH L. SCHROEDER, Defendant. Case No. C 07 3798 JW (HRL) DEFENDANT KENNETH SCHROEDER'S AND NON-PARTY KLA-TENCOR CORPORATION'S STIPULATION AND [PROPOSED] XXXXXXXXXORDER TO SHORTEN TIME ON KLA-TENCOR CORPORATION'S MOTION FOR PROTECTIVE ORDER MAGISTRATE JUDGE HOWARD R. LLOYD DATE: TIME: DEPT.: FEBRUARY 12, 2008 10:00 A.M. COURTROOM 2, 5TH FLOOR (SJ)

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STIPULATION AND [PROPOSED] ORDER TO SHORTEN TIME (C 07 3798 JW (HRL))
Dockets.Justia.com

Case 5:07-cv-03798-JW

Document 54

Filed 02/08/2008

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MORGAN, LEWIS & BOCKIUS LLP
A T T O R N E Y S A T LAW S A N FR A N C I S C O

STIPULATION AND PROPOSED ORDER Non-party KLA-Tencor Corporation ("KLA") and Defendant Kenneth L. Schroeder respectfully submit this Stipulation and [Proposed] Order, pursuant to N.D. Cal. Civil Local Rules 6-2 and 7-12, asking the Court to hear KLA's Motion for a Protective Order on shortened time. WHEREAS KLA intends to file a Motion for a Protective Order seeking to postpone the deposition of its current and former officers, directors, employees, which Schroeder intends to oppose; WHEREAS Schroeder has served a subpoena on former KLA director and officer Kenneth Levy commanding him to appear for deposition on February 14, 2008; WHEREAS Schroeder has served deposition subpoenas on certain other current and former KLA officers, directors and employees commanding them to appear for deposition on various dates between now and March 31, 2008; WHEREAS KLA and Schroeder agree that it is in their best interests for KLA's Motion for a Protective Order to be heard before the depositions of Kenneth Levy and the other current and former KLA officers, directors and employees. IT IS HEREBY STIPULATED AND AGREED: 1. Subject to the Court's discretion, KLA's Motion for a Protective Order will be

heard on February 12, 2008 at 10:00 a.m. in this Court. KLA will file its Motion for a Protective Order on February 6, 2008. Schroeder's Opposition will be due February 11, 2008.

DATED: February 6, 2008

MORGAN, LEWIS & BOCKIUS LLP By: /s/ Thomas R. Green

Attorneys for Non-Party KLA-Tencor Corporation

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STIPULATION AND XXXXXXXORDER [PROPOSED] TO SHORTEN TIME (C 07 3798 JW (HRL))

Case 5:07-cv-03798-JW

Document 54

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A T T O R N E Y S A T LAW S A N FR A N C I S C O

DATED: February 6, 2008

DLA PIPER US LLP

By:

/s/ Jeffrey B. Coopersmith

Attorneys for Defendant Kenneth L. Schroeder

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED: at 10:00 a.m. in Courtroom 2. 1. KLA's Motion for a Protective Order will be heard on February 12, 2008. KLA ^ will file its Motion for a Protective Order on February 6, 2008. Schroeder's Opposition will be due February 11, 2008. by noon. ^ .

8 Dated: February __, 2008 Hon. Howard R. Lloyd United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER XXXXXXX TO SHORTEN TIME (C 07 3798 JW (HRL))