Thieriot v. Aig Matched Funding et al

Filing 94

STIPULATION AND ORDER RE: 92 TO EXTEND TIME TO SUBMIT REPORT PURSUANT TO APRIL 29, 2009 HEARING (rslc2, COURT STAFF) (Filed on 5/8/2009)

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LUKENS LAW GROUP WILLIAM M. LUKENS (SBN 037196) [e-mail] JENNIFER L. JONAK (SBN 191323) [e-mail] MAUREEN MCGUIRL (SBN 104071) [e-mail] One Maritime Plaza, Suite 1600 San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Richard T. Thieriot H. JOSEPH ESCHER III (SBN85551) [e-mail] FRANCE JAFFE (SBN 217471) [e-mail] DECHERT LLP One Maritime Plaza, Suite 2300 San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants AIG Matched Funding Corp., et al.

*E-Filed 5/8/09* *E-Filed 5/9/09*

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION RICHARD T. THIERIOT, an individual, Plaintiff, v. AIG MATCHED FUNDING CORP., a corporation, et. al., Defendants. ) ) ) ) ) ) ) ) ) ) Case No.: C-07-05069 JW RS STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT REPORT PURSUANT TO APRIL 29, 2009 HEARING

IT IS HEREBY STIPULATED by and among the parties to this action through their counsel of record as follows: WHEREAS, a hearing on the parties' Motions to Compel was heard on April 29, 2009 before Magistrate Judge Seeborg, and at the hearing Judge Seeborg directed the parties to continue meet and confer efforts and submit a report of unresolved issues on May 6, 2009;
STIPULATION & [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT REPORT (Case No. C-07-5069 JW RS)

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WHEREAS, counsel for the parties have continued meet and confer efforts based upon the guidance Judge Seeborg provided on April 29, 2009 and counsel for parties have reached agreement on a number of their discovery disputes, including production of James Kleier invoices through November 2005, production of certain deposition transcripts in AIG's possession, and the production of certain summary information about other AIG transactions; WHEREAS, three depositions and a mediation in this case are scheduled over the course of this week and next week; WHEREAS, several discovery disputes remain outstanding but will likely be resolved with further meeting and conferring; AND WHEREAS, the parties have not previously requested any extension of time to file the report of outstanding discovery issues and this extension will not otherwise affect the schedule for the case. IT IS HEREBY STIPULATED and the parties request that the Court order the following:

STIPULATION & [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT REPORT (Case No. C-07-5069 JW RS)

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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 28 Dated:

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The time for the parties to submit their report, pursuant to Judge Seeborg's

instructions at the April 29, 2009 hearing, is extended through and including May 18, 2009. Dated: May 5, 2009 LUKENS LAW GROUP William M. Lukens (SBN 037196) Jennifer L. Jonak (SBN 191323) Maureen McGuirl (SBN 104071)
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One Maritime Plaza, Suite 1600 San Francisco, CA 94111 Attorneys for Plaintiff Richard T. Thieriot DECHERT LLP H. Joseph Escher II (SBN 85551) France Jaffe (SBN 217471)
/S _________________________ H. JOSEPH ESCHER, III

One Maritime Plaza, Suite 2300 San Francisco, CA 94111 Attorneys for Defendants AIG Funding Corp., AIG Financial Securities Corp., AIG Financial Products Corp., and Banque AIG PURSUANT TO STIPULATION, IT IS SO ORDERED
5/8/09

, 2009

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The Honorable Richard Seeborg United States Magistrate Judge

STIPULATION & [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT REPORT (Case No. C-07-5069 JW RS)

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