Free Stipulation - District Court of California - California

Case 3:07-cv-04908-MHP

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Filed 12/31/2007

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KATHARINE H. PARKER, Appearance Pro Hac Vice PROSKAUER ROSE LLP 1585 Broadway New York, NY 10036-8299 Telephone: 212.969.3000 Fax: 212.969.2900 [email protected] DAWN M. IRIZARRY GEORGE SAMUEL CLEAVER PROSKAUER ROSE LLP 2049 Century Park East 32nd Floor Los Angeles, CA 90067-3206 Telephone 310.557.2900 Fax 310.557.2193 [email protected] [email protected] Attorneys for Defendant Cendant Corporation Short Term Disability Plan UNITED STATES DISTRICT COURT

13 NORTHERN DISTRICT OF CALIFORNIA 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 JOINT STIPULATION AND [PROPOSED] ORDER C07-04908 MHP v. CENDANT CORPORATION SHORT TERM DISABILITY PLAN, Defendant. JOHN DOE Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C 07 - 04908 MHP JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT CONFERENCE AND REQUEST TO APPEAR BY TELEPHONE

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Case 3:07-cv-04908-MHP

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WHEREAS the Court issued an order on September 21, 2007 setting the Initial Case

2 Management Conference for January 7, 2008; 3 WHEREAS lead counsel for Defendant Cendant Short Term Disability Plan, Katharine

4 Parker, is located in New York, New York and has requested to appear by telephone; 5 WHEREAS counsel for plaintiff John Doe have agreed to Ms. Parker's request and have

6 also agreed to appear by telephone; 7 WHEREAS the Court cannot hold a telephonic Case Management Conference on January

8 7, 2008; 9 WHEREAS the Courtroom Deputy has indicated that the Court is available to hold a

10 telephonic Case Management Conference on January 8, 2008 at 10 AM; 11 WHEREAS Defendant hereby attests that counsel for Plaintiff have authorized Defendant

12 to electronically sign this joint stipulation and request on Plaintiff's behalf, 13 14 IT IS HEREBY STIPULATED AND THE PARTIES HEREBY REQUEST that the Court

15 continue the Initial Case Management Conference to January 8, 2008 at 10 AM and allow the 16 parties to appear by telephone. 17 18 DATED: December 31, 2007 19 20 21 22 23 24 DATED: December 31, 2007 25 26 27 28
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LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C. By: /s/ Teresa S. Renaker Teresa S. Renaker Nina Wasow Attorneys for Plaintiff

PROSKAUER ROSE LLP By: /s/ George Samuel Cleaver Katharine H. Parker Dawn M. Irizarry George Samuel Cleaver Attorneys for Defendant

2 JOINT STIPULATION AND [PROPOSED] ORDER C07-04908 MHP

Case 3:07-cv-04908-MHP

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IT IS HEREBY ORDERED that the Court continue the Initial Case Management Conference to January 8, 2008 at 10 AM and allow the parties to appear by telephone.

DATED: January ___, 2008 The Honorable Marilyn H. Patel Judge of the United States District Court, Northern District of California

3 JOINT STIPULATION AND [PROPOSED] ORDER C07-04908 MHP