United Brands Company, Inc. v. Anheuser-Bush, Inc.

Filing 51

Joint MOTION to Extend Rule 26 Compliance and Case Management Conference Deadlines by Anheuser-Busch, Inc., United Brands Company, Inc.. (Attachments: # 1 Declaration of Bobby Ghajar in Support of Motion to Extend Rule 26 Compliance and Case Management Conference Deadlines)(Ghajar, Bobby) (lmt).

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Daniel G. Lamb (SBN 101685)
[e-mail]
PILLSBURY WINTHROP SHAW PITTMAN LLP
502 West Broadway, Suite 1100
San Diego, CA 92101-3575
Telephone:
[phone]
Facsimile:
[phone]
Richard H. Zaitlen (SBN 63283)
[e-mail]
Bobby A. Ghajar (SBN 198719)
[e-mail]
Marcus D. Peterson (SBN 265339)
[e-mail]
PILLSBURY WINTHROP SHAW PITTMAN LLP
725 South Figueroa Street, Suite 2800
Los Angeles, CA 90017-5406
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
ANHEUSER-BUSCH, INC.

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UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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UNITED BRANDS COMPANY, INC.,
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Plaintiff,

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v.

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ANHEUSER-BUSCH, INC.,
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Defendant.

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Case No. 10-CV-2281-AJB (WMc)
Hon. Anthony J. Battaglia
Courtroom A
Magistrate Judge William McCurine, Jr.
DECLARATION OF BOBBY GHAJAR
IN SUPPORT OF JOINT MOTION TO
EXTEND RULE 26 COMPLIANCE AND
CASE MANAGEMENT CONFERENCE
DEADLINES

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I, Bobby A. Ghajar, declare as follows:

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1.

I am an attorney licensed to practice in the State of California and a partner

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with the law firm of Pillsbury Winthrop Shaw Pittman LLP, representing Defendant

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Anheuser-Busch, Inc. The matters stated below are of my own personal knowledge. If

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Case No. 10-cv-2281-AJB (WMc)

DECLARATION OF BOBBY GHAJAR IN SUPPORT OF
JOINT MOTION TO EXTEND RULE 26 COMPLIANCE
AND CASE MANAGEMENT CONFERENCE
DEADLINES

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called as a witness, I could and would testify competently thereto. I make this Declaration

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in support of the Joint Motion to Extend Rule 26 Compliance and Case Management

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Conference Deadlines.

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2.

My firm has been retained by Anheuser-Busch, Inc. (“A-B”) to assume

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responsibility of this matter and we are substituting into this case. The case documents that

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are in the possession of former counsel are in the process of being transferred. My team

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needs a reasonable opportunity to review those files and confer with the client to put

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together a discovery plan and to comply with the initial disclosure requirement.

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3.

A-B’s office are closed for the holidays until January 4, 2012.

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4.

In the even the Court is unable to accommodate a February 10, 2012 Case

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Management Conference, we ask the Court to move the conference to March 19, 2012 or

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the next available date thereafter. Unfortunately, this postponement is necessary due to pre-

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existing, conflicting pretrial and trial obligations is another case. I currently have a two-

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week jury trial schedule before Judge Collins in the Central District of California beginning

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at the end of February. The final pretrial conference is February 13, 2012 and there are a

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number of deadlines between that date and trial. I am lead trial counsel in that case. The

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trial is expected to run two weeks, although Judge Collins has advised the parties that she

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may need to shorten the trial weeks to accommodate her Chief Judge duties.

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5.

Moreover, I am informed that the client representative would be unable to

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participate in any ENE during the week of February 22, 2012. I appreciate the Court’s

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consideration of my desire to avoid a conflict with the re-scheduled Case Management

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Conference in this case.

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Case No. 10-cv-2281-AJB (WMc)

DECLARATION OF BOBBY GHAJAR IN SUPPORT OF
JOINT MOTION TO EXTEND RULE 26 COMPLIANCE
AND CASE MANAGEMENT CONFERENCE
DEADLINE

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I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.

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Executed at Los Angeles, California, this 23rd of December, 2011.

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Respectfully submitted,
DANIEL G. LAMB, JR
San Diego Office
501 West Broadway, Suite 1100
San Diego, CA 92101

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RICHARD H. ZAITLEN
BOBBY A. GHAJAR
MARCUS D. PETERSON
Los Angeles Office
725 South Figueroa Street, Suite 2800
Los Angeles, CA 90017-5406

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By /s/ Bobby A. Ghajar
Attorneys for Defendant
ANHEUSER-BUSCH, INC.

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Case No. 10-cv-2281-AJB (WMc)

DECLARATION OF BOBBY GHAJAR IN SUPPORT OF
JOINT MOTION TO EXTEND RULE 26 COMPLIANCE
AND CASE MANAGEMENT CONFERENCE
DEADLINE

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CERTIFICATE OF SERVICE
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I hereby certify that on December 23, 2011, I served the above Declaration of
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Bobby Ghajar in Support of Joint Motion to Extend Rule 26 Compliance and Case
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Management Conference Deadlines via the Court’s ECF system to:
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Nancy O. Dix
Brian L. Behmer
Cristina D. Yates
Christopher J. Beal
DLA PIPER LLP (US)
401 B Street, Suite 1700
San Diego, CA 92101-4297
Telephone: [phone]
Fax: [phone]
I declare that I am employed by a member of the bar of this Court, at whose
direction this service was made.

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Dated: December 23, 2011

/s/ Bobby A. Ghajar

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Case No. 10-cv-2281-AJB (WMc)

DECLARATION OF BOBBY GHAJAR IN SUPPORT OF
JOINT MOTION TO EXTEND RULE 26 COMPLIANCE
AND CASE MANAGEMENT CONFERENCE
DEADLINE

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