Free Case Transferred In - District Transfer - District Court of Delaware - Delaware

Case 1:05-cv-00897-JJF Document 20-20 Case 3:05-cv-02858-MHP Document 15

Filed 10/31/2005 Page 11 of 4 Filed 01/18/2006 Page of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14

BINGHAM McCUTCHEN LLP DAVID M. BALABANIAN (SBN 37368) CHRISTOPHER B. HOCKETT (SBN 121539) JOY K. FUYUNO (SBN 193890) Three Embarcadero Center San Francisco, CA 94111-4067 Telephone: (415) 393-2000 Facsimile: (415) 393-2286 Attorneys for Defendant Intel Corporation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

LAW OFFICES OF LAUREL STANLEY, a California business entity, and WILLIAM F. CRONIN, a resident of Texas, Plaintiffs, v. INTEL CORPORATION, a Delaware corporation, Defendant.

No. C-05-2858-MHP STIPULATION AND [PROPOSED] ORDER TO STAY DATES, EVENTS AND DEADLINES PENDING THE OUTCOME OF THE MOTION TO TRANSFER AND COORDINATE OR CONSOLIDATE PURSUANT TO 28 U.S.C. § 1407

15 16 17 18 19 20 21 22 23 24 25 26
SF/21642103.1

WHEREAS, on July 13, 2005, Plaintiffs filed the instant action in the Northern District of California ("Stanley Action"); WHEREAS, on or about July 11, 2005, the plaintiffs in Brauch, et al. v. Intel Corp., No. C 05-2743 (BZ) (N. D. Cal., filed July 5, 2005), a related matter, moved before the Judicial Panel on Multi-District Litigation ("MDL"), to transfer and coordinate or consolidate for pre-trial proceedings pursuant to 28 U.S.C. § 407 ("MDL Motion"), and the Stanley Action has been identified as a related action subject to that motion;

Case No. C 05-2858 (MHP)

STIPULATION AND [PROPOSED] ORDER TO STAY DATES, EVENTS AND DEADLINES

Case 1:05-cv-00897-JJF Document 20-20 Case 3:05-cv-02858-MHP Document 15

Filed 10/31/2005 Page 22 of 4 Filed 01/18/2006 Page of 4

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
SF/21642103.1

WHEREAS, on or about July 27, 2005, Judge Patel issued a Related Case Order relating this case to an earlier filed case assigned to her, and canceling or staying certain but not all dates, events and deadlines in the action; WHEREAS, to date, a decision has not been rendered on the MDL Motion; WHEREAS, the outcome of the MDL Motion will impact significantly the schedule of this case; THEREFORE, IT IS HEREBY STIPULATED, pursuant to Civil Local Rule 6-2, by and among counsel for Stanley Plaintiffs, and counsel for Defendant Intel Corporation, that any events, dates or deadlines set by the Local Rules or Federal Rules of Civil Procedure, including the Local Rules for Alternative Dispute Resolution ("ADR Local Rules") and Federal Rules of Civil Procedure 16 and 26, and any deadlines established in any case management order applicable to this case should be stayed pending the outcome of the aforementioned MDL Motion; and IT IS FURTHER STIPULATED by the aforementioned parties that if a case management conference is rescheduled by the Court, the parties shall adjust the dates for any conference, disclosures or reports required by the Local Rules or Federal Rules of Civil Procedure, including the ADR Local Rules and Federal Rules of Civil Procedure 16 and 26 accordingly. IT IS HEREBY STIPULATED.

2

Case No. C 05-2858 (MHP)

STIPULATION AND [PROPOSED] ORDER TO STAY DATES, EVENTS AND DEADLINES

Case 1:05-cv-00897-JJF Document 20-20 Case 3:05-cv-02858-MHP Document 15

Filed 10/31/2005 Page 33 of 4 Filed 01/18/2006 Page of 4

1 2 3 4 5 6 7 8 9 10 11 Dated: October 31, 2005 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 By: /s/ Joy K. Fuyuno Joy K. Fuyuno Attorneys for Defendant Intel Corporation BINGHAM McCUTCHEN LLP Dated: October 31, 2005 THE FURTH FIRM LLP LAW OFFICES OF FRANCIS O. SCARPULLA ZELLE, HOFFMANN, VOELBEL, MASON & GETTE LLP KELLOGG, HUBER, HANSEN, TODD, EVANS & FIGEL, P.L.L.C. By: /s/ Alex C. Turan________ Alex C. Turan Attorneys for Plaintiff Law Offices of Laurel Stanley and William F. Cronin

[PROPOSED] ORDER TO STAY DATES, EVENTS AND DEADLINES PENDING THE OUTCOME OF THE MDL MOTION Any events, dates or deadlines set by the Local Rules or Federal Rules of Civil Procedure, including the Local Rules for Alternative Dispute Resolution ("ADR Local Rules") and Federal Rules of Civil Procedure 16 and 26, and any deadlines established in any case management order applicable to this case are hereby stayed pending the outcome of the motion to transfer and coordinate or consolidate pursuant to 28 U.S.C. § 1407 ("MDL Motion"). Upon the determination of the MDL Motion, if it is necessary for the Court to reschedule a case management conference, the parties shall adjust the dates for any conference, disclosures or reports required by the ADR Local Rules and Federal Rules of Civil Procedure 16 and 26 accordingly.
SF/21642103.1

3

Case No. C 05-2858 (MHP)

STIPULATION AND [PROPOSED] ORDER TO STAY DATES, EVENTS AND DEADLINES

Case 1:05-cv-00897-JJF Document 20-20 Case 3:05-cv-02858-MHP Document 15

Filed 10/31/2005 Page 44 of 4 Filed 01/18/2006 Page of 4

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
SF/21642103.1

The parties shall notify the Clerk of Court within 10 days of the decision on the MDL Motion. IT IS SO ORDERED. Dated: Honorable Marilyn H. Patel United States District Court Judge

4

Case No. C 05-2858 (MHP)

STIPULATION AND [PROPOSED] ORDER TO STAY DATES, EVENTS AND DEADLINES