Google Inc. et al v. Egger et al

Filing 287

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Google Inc. et al v. Egger et al Doc. 287 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 Elizabeth J. Cabraser (State Bar No. 083151) Barry R. Himmelstein (State Bar No. 157736) Michael W. Sobol (State Bar No. 194857) Eric B. Fastiff (State Bar No. 182260) Allison S. Elgart (State Bar No. 241901) LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP 275 Battery Street, 30th Floor San Francisco, CA 94111-3339 Telephone: (415) 956-1000 Facsimile: (415) 956-1008 Interim Class Counsel for MCI Class [Additional Counsel Appear On Signature Page] UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (San Francisco Division) IN RE NATIONAL SECURITY AGENCY TELECOMMUNICATIONS RECORDS LITIGATION ___________________________________ THIS DOCUMENT RELATES TO: All Class Actions Against the MCI and Verizon Defendants; Bready, et al. v. Verizon Maryland (No. 06-06313); Chulsky, et al. v. Cellco Partnership dba Verizon Wireless (No. 06-06570); and Riordan, et al. v. Verizon Communications (No. 06-3574) MDL Docket No. 06-1791 (VRW) STIPULATION AND [PROPOSED] ORDER MODIFYING BRIEFING SCHEDULE AND HEARING DATE FOR VERIZON MOTIONS TO DISMISS Courtroom: 6, 17th Floor Judge: Hon. Vaughn R. Walker 626326.1 STIP. RE VERIZON MOTIONS TO DISMISS MDL DOCKET NO. 06-1791 (VRW) Dockets.Justia.com 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 STIPULATION WHEREAS, by order dated March 22, 2007, the Court granted the Government's opposed motion to extend and set a briefing and hearing schedule on dispositive motions in cases asserting claims against the Verizon defendants. (Dkt. No. 217); WHEREAS, on April 20, 2007, the United States filed an unclassified memorandum in support of its motion to dismiss or for summary judgment on state secrets grounds (Dkt. Nos. 253-257); WHEREAS, on April 30, 2007, the Verizon defendants filed amotion to dismiss the Master Consolidated Complaint (Dkt. No. 125); a motion to dismiss the Chulsky, Riordan, and Bready complaints (Dkt. No. 270-271); and a motion to dismiss for lack of personal jurisdiction (Dkt. No. 268-269); WHEREAS, under the schedule set by the Court in its March 22, 2007 Order, Plaintiffs have until May 24, 2007, to file their oppositions to the foregoing motions; WHEREAS, Plaintiffs desire additional time to respond to the foregoing motions, which would require an adjustment of the June 21, 2007 hearing date; WHEREAS the Government and Verizon Defendants previously sought to work cooperatively on a schedule in the Verizon cases and are willing to consent to this requested extension; WHEREAS, the parties are advised that the Court is not available to hear the foregoing motions at a later date until August 9, 2007, and is not available to hear the foregoing motions on August 23, 2007; and WHEREAS, counsel for the Verizon defendants and the United States have scheduling conflicts that preclude resetting the hearings for August 9, 2007 or the week of 13-17, 2007; IT IS HEREBY STIPULATED AND AGREED, SUBJECT TO APPROVAL OF THE COURT, THAT: (1) foregoing motions; 626326.1 Plaintiffs shall have until June 22, 2007 to file their oppositions to the -1- STIP. RE VERIZON MOTIONS TO DISMISS MDL DOCKET NO. 06-1791 (VRW) 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 626326.1 (2) The Verizon defendants and the United States shall have until August 3, 2007 to file their reply briefs in support of the foregoing motions; (3) (4) The foregoing motions will be heard on August 30, 2007; The United States' administrative motion for leave to file a 58-page redacted opening brief in support of its motion to dismiss (Dkt. No. 258) is granted, nunc pro tunc; (5) The MCI and Verizon class plaintiffs shall have a total of 108 pages for their oppositions to the United States' motion to dismiss and the Verizon defendants' motion to dismiss the Master Consolidated Complaint; (6) The Verizon defendants shall have 40 pages for their reply in support of their motion to dismiss the Master Consolidated Complaint; (7) The page limit for the United States' reply in support of its motion to dismiss will be addressed by separate stipulation or, if necessary, motion; and (8) Dated: May 22, 2007 The length of other briefs shall remain as governed by applicable rules. Respectfully submitted, By: \s\ Barry R. Himmelstein Barry R. Himmelstein LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP Interim Class Counsel for MCI Class By: \s\ Jodi W. Flowers Jodi W. Flowers MOTLEY RICE, LLC Interim Class Counsel for Verizon Class -2- STIP. RE VERIZON MOTIONS TO DISMISS MDL DOCKET NO. 06-1791 (VRW) 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 626326.1 By: \s\ Ann Brick Ann Brick AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF NORTHERN CALIFORNIA Attorneys for Plaintiffs in Riordan, et al. v. Verizon Communications, Inc. By: \s\ John A. Rogovin John A. Rogovin WILMER CUTLER PICKERING HALE AND DORR LLP Attorneys for Verizon Defendants By: \s\ Anthony J. Coppolino Anthony J. Coppolino U.S. DEPARTMENT OF JUSTICE Attorneys for the United States of America By: \s\ Joshua G. Whitaker Joshua G. Whitaker GRIFFIN WHITAKER LLP Attorneys for Plaintiffs in Bready, et al. v. Verizon Maryland, Inc. By: \s\ David H. Sternlieb David H. Sternlieb SHAPIRO & STERNLIEB, LLC Attorneys for Plaintiffs in Chulsky, et al. v. Cellco Partnership dba Verizon Wireless Pursuant to General Order 45, Part X-B, the filer attests that concurrence in the filing of this document has been obtained from Jodi W. Flowers, Ann Brick, John A. Rogovin, Anthony J. Coppolino, Joshua G. Whitaker, and David H. Sternlieb. -3- STIP. RE VERIZON MOTIONS TO DISMISS MDL DOCKET NO. 06-1791 (VRW) 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 626326.1 PROPOSED ORDER Pursuant to the foregoing stipulation (1) (8), IT IS SO ORDERED. The motions that are the subject of the stipulation will be heard on August 30, 2007 at 2:00 p.m. Dated: May __, 2007 ________________________________________ Hon. Vaughn R. Walker United States District Chief Judge -4- STIP. RE VERIZON MOTIONS TO DISMISS MDL DOCKET NO. 06-1791 (VRW)

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