Jackson v. Atlanta Falcons Football Club

Filing 7

PROPOSED CONSENT ORDER Staying Discovery. (Boyd, Matthew)

Jackson v. Atlanta Falcons Football Club

Doc. 7

Case 1:07-cv-00939-GET

Document 7

Filed 05/14/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION GRADY JACKSON, Plaintiff, v. ATLANTA FALCONS FOOTBALL CLUB, LLC Defendant. ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO: 07-CV-0939-GET

CONSENT ORDER Currently pending before the Court is Defendant's dispositive Motion To Dismiss or To Compel Arbitration. Counsel for Plaintiff has represented to the Court that Plaintiff intends to oppose that Motion and also intends to file a Motion to Remand this case to the Superior Court for Fulton County, Georgia. Given the dispositive nature of both Defendant's pending Motion and Plaintiff's anticipated Motion for Remand, the parties have agreed that judicial economy will be served by staying all other proceedings (including the parties' Rule 26(f) obligations) until such motions have been considered and resolved by the Court. The Court agrees, and it is therefore ORDERED that, other than filing response and/or reply briefs to Defendant's currently pending motion and/or Plaintiff's anticipated motion for

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remand (and the filing of any motions for admission pro hac vice), all other matters are stayed. Should any matters remain pending following the Court's resolution of the above-referenced motions, the parties shall conduct their Fed. R. Civ. P. 26(f) conference no more than ten (10) days after the Court rules on Defendant's pending Motion, or Plaintiff's anticipated Motion for Remand, whichever is later. Respectfully submitted this 14th day of May, 2007. s/ Matthew A. Boyd Michael W. Johnston Georgia Bar No. 396720 Matthew A. Boyd Georgia Bar No. 027645 Amanda C. Kunz Georgia Bar No. 142177 KING & SPALDING LLP 1180 Peachtree Street NE Atlanta, Georgia 30309-3521 [phone] (telephone) [phone] (facsimile) [e-mail] [e-mail] [e-mail] ATTORNEYS FOR THE ATLANTA FALCONS FOOTBALL CLUB, LLC Consented to: s/ Kenan G. Loomis Kenan G. Loomis Georgia Bar No. 457865 COZEN O'CONNOR 2

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SunTrust Plaza, Suite 2200 303 Peachtree Street, N.E. Atlanta, Georgia 30308 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR PLAINTIFF GRADY JACKSON

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Case 1:07-cv-00939-GET

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION GRADY JACKSON, Plaintiff, v. ATLANTA FALCONS FOOTBALL CLUB, Defendant. ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO: 07-CV-0939-GET

CERTIFICATE OF SERVICE I hereby certify that I electronically filed the CONSENT ORDER with the Clerk of Court using the CM/ECF system which will automatically send email notification of such filing to the following attorney of record: Kenan G. Loomis COZEN O'CONNOR SunTrust Plaza, Suite 2200 303 Peachtree Street, N.E. Atlanta, Georgia 30308 I also here certify that I have mailed by United States Postal Service the document to the following non-CM/ECF participants: Eric Farber Ann McFarland Draper FARBER & COMPANY ATTORNEYS LLP 847 Sansome Street, Suite LL San Francisco, California 94111 This 14th day of May, 2007.

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s/ Matthew A. Boyd Matthew A. Boyd Georgia Bar No. 027645

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