Rocky Mountain Bank -v- Google, Inc.

Filing 45

Reply Memorandum re 42 MOTION to Unseal Document, 40 MOTION to Intervene filed byMediaPost Communications. (Craven-Green, Erica) (Filed on 11/20/2009)

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Rocky Mountain Bank -v- Google, Inc. Doc. 45 1 MEISELMAN, DENLEA, PACKMAN, 2 Jeffrey I. Carton (pro hac vice) 3 Christine M. Ford (pro hac vice) 4 White Plains, New York 10605 CARTON & EBERZ P.C. Jerome Noll (pro hac vice) 1311 Mamaroneck Avenue (914) 517-5000 5 6 CALDWELL LESLIE & PROCTOR, PC 7 Crowther@caldwell-leslie.com 8 Giang@caldwell-leslie.com ROBYN C. CROWTHER, SBN 193840 ALBERT GIANG, SBN 224332 1000 Wilshire Blvd., Suite 600 Telephone: (213) 629-9040 9 Los Angeles, California 90017-2463 10 Facsimile: (213) 629-9022 11 Attorneys for Plaintiffs 12 13 14 and all others similarly situated UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA Case No. C-08-04969 JF 15 REUBEN BERENBLAT, ANDREW PERSONETTE, EARL C. SIMPSON, 16 LAURA MILLER, On behalf of themselves and all others similarly situated, 17 18 19 20 21 22 23 24 25 26 27 28 CALDWELL LESLIE & PROCTOR Plaintiffs, v. APPLE INC., Defendants. STIPULATION AND [PROPOSED] ORDER REQUESTING CONTINUANCE OF CASE MANAGEMENT CONFERENCE Pursuant to Local Rules 6-2, 7-12 and 16-2(e), the parties, by and through their respective counsel, hereby stipulate and request as follows: WHEREAS, Plaintiffs filed a First Amended Complaint on April 2, 2009; WHEREAS, Defendant filed its Motion to Dismiss (the "Motion") on June 1, 2009; WHEREAS, the Motion is currently noticed for hearing on August 14, 2009; -1STIPULATION AND PROPOSED ORDER Case No. C-08--4969 JF Dockets.Justia.com 1 WHEREAS, in accordance with a Stipulation and Order dated February 26, 2009, 2 the Court scheduled a Case Management Conference for June 19, 2009; 3 WHEREAS, for the convenience of counsel and the Court the parties request that 4 the Case Management Conference and hearing on the Motion be held on the same date, 5 August 14, 2009; 6 WHEREAS, the continuance of the Case Management Conference will not affect 7 any other deadlines in this action; 8 NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED that, upon an 9 order from the Court as required under Local Rule 16-2(e), the Case Management 10 Conference currently scheduled for June 19, 2009 shall be continued to August 14, 2009. 11 12 13 14 15 16 17 18 19 20 Filer's Attestation: Pursuant to General Order No. 45.1, I, Robyn C. Crowther attest that I 21 22 23 24 25 26 27 28 CALDWELL LESLIE & PROCTOR Dated: June 4, 2009 Caldwell Leslie & Proctor, PC By: /s/ Robyn C. Crowther Robyn C. Crowther Attorneys for Plaintiff Dated: June 4, 2009 Morrison & Foerster LLP By: /s/ Andrew D. Muhlbach Andrew D. Muhlbach Attorneys for Defendant obtained concurrence in the filing of this document from the other signatories. PROPOSED ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: June __, 2009 _____________________________ The Honorable Jeremy Fogel United States District Judge -2STIPULATION AND PROPOSED ORDER Case No. C-08--4969 JF

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