Pravin et al v. Wipro, Inc.

Filing 72

STIPULATION AND ORDER RE: 69 TO RESCHEDULE FURTHER CASE MANAGEMENT CONFERENCE AS MODIFIED BY THE COURT. Further Case Management Conference set for 5/26/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 3/23/11. (cl, COURT STAFF) (Filed on 3/24/2011)

*E-Filed 3/24/11* 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Plaintiffs, 17 vs. 18 19 20 21 22 23 24 25 26 27 28 Case No. 5:09-CV-02743 RS Stipulation and [Proposed] Order To Adjourn and Reschedule Further Case Management Conference
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STEPHEN E. MORRISSEY (187865) SUSMAN GODFREY L.L.P. 1901 Avenue of the Stars, Suite 950 Los Angeles, CA 90067-6029 Telephone: [phone] Fax: [phone] Email: [e-mail] DANIEL J. WALKER (admitted pro hac vice) SUSMAN GODFREY L.L.P. 1201 Third Avenue, Suite 3800 Seattle, WA 98101-3000 Telephone: [phone] Fax: [phone] Email: [e-mail] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION PRAVIN JAIN, RANDY HOLTHAUS, DILIP KUKREJA, MARK WARNER, and DOUGLAS TANNER, Case No.: 5:09-cv-02743-RS STIPULATION AND [PROPOSED] ORDER TO ADJOURN AND RESCHEDULE FURTHER CASE MANAGEMENT CONFERENCE AS MODIFIED BY THE COURT

WIPRO, INC., a Delaware corporation, and DOES 1 THROUGH 100, Defendants.

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Plaintiffs Pravin Jain, Randy Holthaus, Dilip Kukreja, Mark Warner, and Douglas Tanner (collectively "Plaintiffs") and Defendant Wipro, Inc. ("Wipro") agree and stipulate as follows: As Part of the Scheduling Order entered on March 3, 2011, the Court set a Further Case Management Conference for March 31, 2011 rather than the April 21, 2011 date proposed by the parties; Lead counsel for Plaintiffs, Stephen Morrissey' hopes to attend any Further Case Management Conference, but has a scheduling conflict with a previously arranged family trip on March 31, 2011; Additionally, under the current schedule, the parties' oppositions to the pending crossmotions for summary judgment are due on April 1, 2011, the day after the currently scheduled Further Case Management Conference, and traveling to San Francisco for a Conference on March 31 would complicate the parties' preparation for that filing; The parties believe that holding the Conference in April 2011 will allow them more time to identify issues that should be addressed at the Conference; The parties accordingly propose continuing the Further Case Management Conference to April 7, 2011, or such later date as may be convenient for the Court; Consequently, IT IS HEREBY STIPULATED between Plaintiffs and Wipro, through their respective counsel of record, and pursuant to Civil Local Rule 6-2, that, to the extent allowed by the Court's calendar, the dates set forth in the Scheduling Order entered on March 3, 2011 should be modified to adjourn the Further Case Management Conference now scheduled for March 31, 2011 and reset it for April 7, 2011 or such later date as may be convenient for the Court.

1 Case No. 5:09-CV-02743 RS Stipulation To and [Proposed] Order To Adjourn and Reschedule Further Case Management Conference
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IT IS SO STIPULATED. Dated: March 23, 2011 SUSMAN GODFREY LLP

By:

/s/ Stephen E. Morrissey

Stephen E. Morrissey (187865) 1901 Avenue of the Stars, Suite 950 Los Angeles, CA 90067-6029 [phone] [phone] (fax) Email: [e-mail] Daniel J. Walker (admitted pro hac vice) SUSMAN GODFREY L.L.P. 1201 Third Avenue, Suite 3800 Seattle, Washington 98101-3000 [phone] [phone] (fax) Email: [e-mail] Attorneys for Plaintiffs Dated: March 23, 2011 MICHAEL J. IOANNOU DANIEL P. MCKINNON ROPERS, MAJESKI, KOHN & BENTLEY By: /s/ Michael J. Ioannou (with permission) Michael J. Ioannou Attorneys for Defendant Wipro, Inc.

I, Stephen E. Morrissey, am the ECF user whose identification and password are being used to file this [proposed] order re stipulation to modify case schedule. In compliance with General Order 45.X.B, I hereby attest that the other signatory has concurred in this filing. Dated: December 14, 2010 SUSMAN GODFREY L.L.P.

By: /s/ Stephen E. Morrissey Stephen E. Morrissey Attorneys for Plaintiffs Pravin Jain, Randy Holthaus, Dilip Kukreja, Mark Warner, And Douglas Tanner 2 Case No. 5:09-CV-02743 RS Stipulation To and [Proposed] Order To Adjourn and Reschedule Further Case Management Conference
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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 3/23 Dated: ______________, 2011

[PROPOSED] ORDER Pursuant to stipulation, IT IS HEREBY ORDERED, that the Further Case Management Conference previously scheduled for March 31, 2011 is adjourned, and a Further Case May 26, Management Conference shall be held on April __, 2011 at 10:00 a.m. All other dates in the Modified Scheduling Order entered on March 3, 2011 shall remain the same.

By: Honorable Richard Seeborg UNITED STATES DISTRICT JUDGE

3 Case No. 5:09-CV-02743 RS Stipulation To and [Proposed] Order To Adjourn and Reschedule Further Case Management Conference
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