Kalinowski v. T-Mobile, USA, Inc.

Filing 18

STIPULATION AND ORDER AS MODIFIED BY THE COURT Continuing Initial Case Management Conference and ADR Deadlines re 17 Stipulation. Joint Case Management Conference statement due 11/6/2009. Initial Case Management Conference set for 11/16/2009 10:00 AM in Courtroom 8, 4th Floor, San Jose before Hon. James Ware. Signed by Judge James Ware on 9/14/2009. (ecg, COURT STAFF) (Filed on 9/14/2009)

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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 BINGHAM McCUTCHEN LLP JAMES SEVERSON (SBN 67489) JACQUELINE BRONSON (SBN 222169) E-mail: james.severson@bingham.com E-mail: jacqueline.bronson@bingham.com Three Embarcadero Center San Francisco, CA 94111-4067 Phone: (415) 393-2000 Fax: (415) 393-2286 Attorneys for Defendant T-MOBILE USA, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION MARINA KALINOWSKI, Plaintiff, v. T-MOBILE USA, INC., and DOES 1 through 10, Defendants. Case No. 09-cv-02322-JW STIPULATION AND [PROPOSED] ORDER TO MODIFY ORDER SETTING INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES Complaint Filed: Trial Date: April 24, 2009 None Set Plaintiff Marina Kalinowski and Defendant T-Mobile hereby jointly request that the Court modify its May 26, 2009 and May 28, 2009 orders which collectively set a case management conference for this case on October 5, 2009 and corresponding ADR and Federal Rule of Civil Procedure 26 deadlines. Whereas, the parties have agreed to engage in settlement discussions in order to expeditiously resolve this case. Whereas, the parties agree that it would aid in settlement discussions if the case management conference and corresponding dates are reset to approximately one month later. THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between the parties, that: The last date to meet and confer regarding initial disclosures, ADR process selection, and Case No.: C09-02322 STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE A/73138416.1/3000083-0000340313 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 a discovery plan is November 2, 2009. The last date to file a Rule 26(f) report, complete initial disclosures or state objection in Rule 26(f) report, and file Joint Case Management Statement is November 6 2009. 9, The case management conference is reset to November 16th at 10:00 am. DATED: September 8, 2009 BINGHAM McCUTCHEN LLP By: /s/ James Severson James Severson Jacqueline Bronson Attorneys for Defendant T-MOBILE USA, INC. DATED: September 8, 2009 SWEENEY, MASON, WILSON & BOSOMWORTH By: /s/ Kurt E. Wilson Kurt E. Wilson Attorneys for Plaintiff IT IS SO ORDERED. AS MODIFIED. Dated: September 14, 2009 Hon. James Ware 2 A/73138416.1/3000083-0000340313 Case No.: C09-02322 STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE

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