Free Motion to Continue - District Court of California - California

Case 3:08-cv-01277-L-AJB

Document 7

Filed 08/27/2008

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Aton Arbisser, Bar No. 150496 Jonathan M. Rotter, Bar No. 234137 KAYE SCHOLER LLP 1999 Avenue of the Stars, Suite 1700 Los Angeles, California 90067 Telephone: (310) 788-1000 Facsimile: (310) 788-1200 [email protected] Attorneys for Defendant Pfizer Inc

6 7 8 9 Thomas F. Landers, Bar No. 207335 SOLOMON WARD SEIDENWURM & SMITH, LLP 401 B Street, Suite 1200 San Diego, California 92101 Telephone: (619) 231-0303 Facsimile: (619) 231-4755 [email protected] Attorneys for Plaintiff James R. Huck

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Following the Court's Order to Continue the Early Neutral Evaluation Conference dated August 14, 2008, counsel for all parties jointly move to further continue the ENE for a short time. Defendant contacted chambers and was informed that Tuesday, October 7, 2008, at 1:30 p.m., is available. Accordingly, the parties request the Court continue the ENE to October 7, 2008, at 1:30 p.m.
23251237.DOC JOINT MOTION TO CONTINUE EARLY NEUTRAL EVALUATION CONFERENCE TO OCTOBER 7, 2008

K aye S choler

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA

JAMES R. HUCK dba HUMAN RESOURCES INTERNATIONAL, Plaintiff, v. PFIZER INC, A DELAWARE CORPORATION, DOES 1 THROUGH 50, INCLUSIVE, Defendants.

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Civil No. 08cv1277 L (ABJ) JOINT MOTION TO CONTINUE EARLY NEUTRAL EVALUATION CONFERENCE TO OCTOBER 7, 2008 Currently Scheduled ENE: September 16, 2008, 10:00 a.m. Hon. Anthony J. Battaglia

Case 3:08-cv-01277-L-AJB

Document 7

Filed 08/27/2008

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The motion is made (1) to accommodate the schedule of defendant's intended party participant, whose attendance at the ENE would be most conducive to its success, and who is not available on the currently scheduled date, and (2) in light of continuing discussions and exchange of information between the parties. The parties have been engaging in productive discussions and information exchange, and the additional time for further exchange will enhance the efficacy and efficiency of the ENE. The parties remain committed to an ENE that is as meaningful and productive as possible. The parties further request the current deadlines to file their briefs be extended. Plaintiff's brief will be due September 18 and Defendant's brief will be due September 26, 2008, which will have them in the Court's possession the same amount of time in advance as under the current schedule. DATED: August 27, 2008 KAYE SCHOLER LLP By: /s/ Jonathan Rotter Aton Arbisser Jonathan M. Rotter Email address: [email protected] Attorneys for Defendant Pfizer Inc

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K aye S choler

DATED: August 27, 2008

SOLOMON WARD SEIDENWURM & SMITH, LLP By: /s/ Thomas Landers Thomas Landers Email address: [email protected] Attorneys for Plaintiff James R. Huck

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23251237.DOC JOINT MOTION TO CONTINUE EARLY NEUTRAL EVALUATION CONFERENCE TO OCTOBER 7, 2008

Case 3:08-cv-01277-L-AJB

Document 7

Filed 08/27/2008

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CERTIFICATE OF SERVICE I hereby certify that on the 27th day of August, 2008, I will electronically file the foregoing with the Clerk of the Court using the CM/ECF system, which will then send a notification of such filing (NEF) to the following: Thomas F. Landers SOLOMON WARD SEIDENWURM & SMITH, LLP 401 B Street, Suite 1200 San Diego, CA 92101 (619) 231-0303 /s/ Jonathan Rotter Jonathan M. Rotter Attorney for Defendant Pfizer Inc. KAYE SCHOLER LLP 1999 Avenue of the Stars, Suite 1700 Los Angeles, CA 90067 TEL: (310) 788-1000 FAX: (310) 788-1200 [email protected]

K aye S choler

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23251237.DOC JOINT MOTION TO CONTINUE EARLY NEUTRAL EVALUATION CONFERENCE TO OCTOBER 7, 2008