Sarkis v. Lajcak et al

Filing 34

STIPULATION AND ORDER #32 Continuing Case Management Conference and Due Date for Specially Appearing Defendants' Reply to Opposition to motion to Dismiss.Case Management Conference set for 12/19/2008 10:30 AM. Signed by Judge Jeremy Fogel on 10/28/08. (jg, COURT STAFF) (Filed on 10/28/2008)

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BAKER & H OSTETLER LLP
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JEFFREY M. FORSTER, Bar No. 50519 LAW OFFICES OF JEFFREY M. FORSTER 160 West Santa Clara Street, Suite 1100 San Jose, California 95113 Telephone: [phone] Facsimile: [phone] Email: [e-mail] PHILIP M. MUSOLINO (Pro Hac Vice) MUSOLINO & DESSEL 1615 L Street NW, Suite 440 Washington, DC 20036 Telephone: [phone] Facsimile: [phone] Email: pmuso lino @muso linoanddessel.co m Attorneys for Plaintiff ANTHONY SARKIS LISA I. CARTEEN, Bar No. 204764 BAKER & HOSTETLER LLP 12100 Wilshire Boulevard, 15th Floor Los Angeles, California 90025-7120 Telephone: [phone] Facsimile: 310.820.8859 Email: [e-mail] m MARK A. CYMROT, Bar No. 164673 (Pro Hac Vice) BAKER & HOSTETLER LLP 1050 Connecticut Avenue, NW, Suite 1100 Washington, DC 20036-5304 Telephone: [phone] Facsimile: 202.861.1783 Email: [e-mail] Attorneys for Specially Appearing Defendants OFFICE OF THE HIGH REPRESENTATIVE and MIROSLAV LAJCÁK, in his capacity as High Representative of the International Community in Bosnia and Herzegovina UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ANTHONY SARKIS, Plaint iff, v. MIROSLAV LAJCAK; OFFICE OF THE HIGH REPRESENTATIVE, Defendants.
C 08 01911 RMW

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BRUCE O. BAUMGARTNER, Bar No. 0025701, (Pro Hac Vice) BAKER & HOSTETLER LLP 312 Walnut Street, Suite 3200 Cincinnat i, Ohio 45202-4072 Telephone: [phone] Facsimile: 513.929.0303 Email: [e-mail]

*E-FILED - 10/28/08*

Case No. C 08 01911 RMW STIPULATION AND [] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND DUE DATE FOR SPECIALLY APPEARING DEFENDANTS' REPLY TO OPPOSITION TO MOTION TO DISMISS [Declarat ion of Lisa I. Carteen filed concurrently herewith]
STIPULATION AND [] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND REPLY DUE DATE

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BAKER & H OSTETLER LLP
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IT IS HEREBY STIPULATED AND AGREED between Plaintiff Anthony Sarkis and Specially Appearing Defendants, by and through their counsel of record, and pursuant to Local Rules 6.1 and 6.2 of the United States District Court for the Northern District of California, that the Case Management Conference scheduled for hearing on November 21, 2008 be postponed to December 19, 2008. If that date is not convenient for the Court, the parties agree that the CMC should be postponed to January 30, 2009. The parties will proceed with the hearing on Defendants' Motion to Dismiss on November 21, 2008 and stipulate that Defendants' Reply to Plaintiff's Opposition must be filed and served on or before November 12, 2008. The parties make this request based on the reasons set out in the Declaration, attached hereto. The parties further agree that by making this Stipulation, Defendants do not waive any jurisdictional objections and reserve all rights, remedies and defenses, including, but not limited to, all defenses raised in their Motion to Dismiss filed August 29, 2008. Dated: October 23, 2008 By: /s/ Lisa I. Carteen Lisa I. Carteen ([e-mail]) (CA #204764) Attorneys for Specially Appearing Defendants OFFICE OF THE HIGH REPRESENTATIVE and MIROSLAV LAJCÁK, in his capacity as High Representative of the International Community in Bosnia and Herzegovina By: /s/ (with permissio n) Jeffrey M. Forster ([e-mail]) (CA #50519) Attorney for Plaintiff ANTHONY SARKIS

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Dated: October 23, 2008

C 08 01911 RMW

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STIPULATION AND [] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND REPLY DUE DATE

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BAKER & H OSTETLER LLP
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ORDER Based on the foregoing Stipulation of the parties, the Declaration of Lisa I. Carteen, submitted herewith, and the facts set forth therein, the Court finds good cause to enter the parties' requested Order. The Case Management Conference is continued to December 19, 2008 at 10:30 a.m. Defendants' Reply to Plaintiff's Opposition to Defendants' Motion to Dismiss must be filed and served on or before November 12, 2008.

10/28/08 Dated: ____________________

FOR _______________________________ Ronald M. Whyte United States District Judge

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C 08 01911 RMW

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STIPULATION AND ] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND REPLY DUE DATE

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BAKER & H OSTETLER LLP
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CERTIFICATE OF SERVICE The undersigned hereby certifies that on October 23, 2008, a true and accurate copy of STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND DUE DATE FOR SPECIALLY APPEARING DEFENDANTS' REPLY TO OPPOSITION TO MOTION TO DISMISS was electronically filed with the Court to be served by operation of the Court's electronic filing system, upon the following: Jeffrey M. Forster ([e-mail]) and Philip M. Musolino ([e-mail]).

Dated: October 23, 2008

BAKER & HOSTETLER LLP /s/ Lisa I. Carteen Lisa I. Carteen Attorneys for Specially Appearing Defendants OFFICE OF THE HIGH REPRESENTATIVE and MIROSLAV LAJCÁK, in his capacity as High Representative of the International Community in Bosnia and Herzegovina

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C 08 01911 RMW 502067712.1

STIPULATION AND [ ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND REPLY DUE DATE