Free Motion for Hearing - District Court of California - California

Case 3:07-cv-02126-BEN-RBB

Document 27

Filed 03/05/2008

Page 1 of 2

1 NANCY SHER COHEN (Bar No. 81706) [email protected] 2 RONALD A. VALENZUELA (Bar No. 210025) [email protected] 3 HELLER EHRMAN LLP 333 South Hope Street, 39th Floor 4 Los Angeles, CA 90071-3043 5 Telephone: +1.213.689.0200 Facsimile: +1.213.614.1868 6 Attorneys for Defendant 7 SONY ELECTRONICS INC. 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA CV No. 07cv2126 - BEN (RBB) JOINT MOTION FOR ORDER SETTING THE HEARING ON PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION AND CLASS CERTIFICATION FOR APRIL 28, 2008 The Honorable Roger T. Benitez Courtroom: 3

11 JASON DEMAS and JOHN RENNINGER, on their own behalves and on behalf of all others 12 similarly situated, 13 Plaintiffs, 14 v. 15 16 SONY ELECTRONICS INC., 17 18 19 20 21 22 23 24 25 26 27 28 Defendant.

Pursuant to Local Rule 7.1(g)(2), Plaintiffs Jason Demas and John Renninger and Defendant Sony Electronics Inc. ("Sony Electronics"), by and through their respective counsel, hereby submit this Joint Motion for an Order re-setting the hearing on Plaintiffs' pending Motion For Preliminary Injunction And Class Certification (the "Motion"). Plaintiffs filed their Motion on November 15, 2007, noticing it for hearing on January 11, 2008. This case was subsequently transferred to this Court from the Honorable Jeffrey T. Miller, and the Court rescheduled the hearing, setting it for February 11, 2008. Subsequently, the parties agreed, and the Court ordered, the hearing be moved to March 24,
JOINT MOT. FOR ORDER SETTING HEARING ON PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION AND CLASS CERTIFICATION FOR APRIL 28, 2008 CV No. 07cv2126 ­ BEN (RBB)

Case 3:07-cv-02126-BEN-RBB

Document 27

Filed 03/05/2008

Page 2 of 2

1 2008. Sony Electronics has not yet filed its Opposition to the Motion. 2 Plaintiffs and Sony Electronics have been, and wish to continue, discussing ways to

3 avoid the need for the Court's intervention on the issues raised by the Motion. Hearing the 4 Motion at a later date would give the parties more time to continue their discussions and 5 could obviate the need for the parties to spend any additional time and resources briefing 6 and arguing the Motion, which would conserve judicial resources. 7 Accordingly, the parties agree that good cause exists for rescheduling the hearing on

8 the Motion and further agree as follows: 9 10 11 12 13 14 15 16 17 18 19 20 21 22 DATED: March 5, 2008 23 24 25 26 27 28 2
JOINT MOT. FOR ORDER SETTING HEARING ON PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION AND CLASS CERTIFICATION FOR APRIL 28, 2008 CV No. 07cv2126 ­ BEN (RBB)

· If the Court determines that oral argument would assist it in deciding Plaintiffs' Motion, the Motion should be heard on April 28, 2008, or as soon thereafter as the matter may be heard by the Court; and · Sony Electronics' Opposition, and Plaintiffs' Reply Brief shall be filed and served in accordance with the Federal Rules of Civil Procedure and the Court's Local Rules. The parties respectfully request that this Joint Motion be granted. Respectfully submitted, DATED: March 5, 2008 HELLER EHRMAN LLP By s/ Ronald A. Valenzuela RONALD A. VALENZUELA Attorneys for Defendant SONY ELECTRONICS INC. KamberEdelson LLC

By s/ Ethan Preston ETHAN PRESTON Attorneys for Plaintiffs