Thieriot v. Aig Matched Funding et al

Filing 98

SECOND JOINT STIPULATION AND ORDER RE: 96 TO EXTEND TIME TO SUBMIT REPORT PURSUANT TO APRIL 29, 2009 HEARING. Status Report due by 6/22/2009. Signed by Magistrate Judge Richard Seeborg on 5/19/09. (rslc2, COURT STAFF) (Filed on 5/19/2009)

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

NICOLLE L. JACOBY (admitted pro hac vice) [e-mail] JOSEPH J. LAVIN (admitted pro hac vice) [e-mail] DECHERT LLP 1095 Avenue of the Americas New York, NY 10036-6797 Telephone: [phone] Facsimile: 212.698.3599 H. JOSEPH ESCHER III (No. 85551) [e-mail] FRANCE JAFFE (No. 217471) [e-mail] DECHERT LLP One Maritime Plaza Suite 2300 San Francisco, CA 94111-3513 Telephone: [phone] Facsimile: 415.262.4555 Attorneys for Defendants AIG MATCHED FUNDING CORP., AIG FINANCIAL SECURITIES CORP., AIG FINANCIAL PRODUCTS CORP., and BANQUE AIG

*E-Filed 5/19/09*

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

RICHARD T. THIERIOT, an individual, Plaintiff, v. AIG MATCHED FUNDING CORP., et al.,

Case No. C-07-05069 JW RS Action Filed: October 7, 2007 SECOND JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT REPORT PURSUANT TO APRIL 29, 2009 HEARING Dep't: Judge: Courtroom 8, 4th Floor Honorable Richard Seeborg

Defendants.

SECOND JOINT STIP. & [PROPOSED] ORDER TO EXTEND TIME

C-07-05069 JW RS

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

Plaintiff Richard T. Thieriot and defendants AIG Matched Funding Corp., AIG Financial Securities Corp., AIG Financial Products Corp., and Banque AIG, through their respective counsel of record, hereby stipulate and agree as follows: WHEREAS, a hearing on the parties' Motions to Compel was heard on April 29, 2009 before the Honorable 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; WHEREAS, on May 5, 2009 parties submitted a Stipulation and Proposed Order to Extend Time to Submit Report requesting that the parties submit their joint report on May 18, 2009 and Judge Seeborg so ordered the Stipulation and Proposed Order on May 8, 2009; WHEREAS, on May 6, 2009, and prior to receiving Judge Seeborg's ruling above, the parties submitted a Joint Report on Discovery Disputes describing the parties' continued meet and confer efforts, setting forth those issues that had been resolved and those issues that remained unresolved as of that date and reiterating the parties' request for an extension through May 18, 2009 to submit a joint report; WHEREAS, on May 13, 2009 parties participated in a private mediation of this matter before the Honorable Layn Phillips (Ret.); WHEREAS, on May 14, 2009 parties submitted a Joint Stipulation and Proposed Order Modifying Case Schedule to Judge Ware requesting a four week extension of the existing case deadlines in order to further explore settlement of this matter; WHEREAS, parties believe that the extension of the existing case deadline and this extension of the deadline to file a report of outstanding issues will allow the parties to direct litigation costs and efforts towards a potential resolution of this matter; WHEREAS, parties have previously requested one extension to the deadlines to submit a report of unresolved issues and this further extension will not otherwise affect the schedule of the case; IT IS HEREBY STIPULATED and the parties request that the Court order the
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SECOND JOINT STIP. & [PROPOSED] ORDER TO EXTEND TIME C-07-05069 JW RS

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

following: 1. The time for the parties to submit their report of unresolved discovery

issues, pursuant to Judge Seeborg's instructions at the April 29, 2009 hearing, is extended through and including June 22, 2009. Dated: May ___, 2009 LUKENS LAW GROUP WILLIAM M. LUKENS JENNIFER L. JONAK MAUREEN MCGUIRL By:

Maureen McGuirl Attorneys for Plaintiff RICHARD T. THERIOT

Dated: May 18, 2009

DECHERT LLP NICOLLE L. JACOBY JOSEPH J. LAVIN H. JOSEPH ESCHER III FRANCE JAFFE By: /s/ H. Joseph Escher III Attorneys for Defendants AIG MATCHED FUNDING CORP., AIG FINANCIAL SECURITIES CORP., AIG FINANCIAL PRODUCTS CORP., and BANQUE AIG

IT IS SO ORDERED.

May 19 Dated: _______________, 2009

The Honorable Richard Seeborg UNITED STATES MAGISTRATE JUDGE

13461375.1.LITI

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SECOND JOINT STIP. & [PROPOSED] ORDER TO EXTEND TIME C-07-05069 JW RS