STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
WHEREAS on September 18, 2008 defendants Mobilefunster, Inc. and Funmobile Games, Inc. ("Defendants") filed a Notice of Removal with this Court;
WHEREAS on September 18, 2008 the Court issued an Order Setting Initial Case Management Conference and ADR Deadlines, which set the Initial Case Management Conference for January 7, 2009 at 3:00 p.m., and related case management deadlines flowing from that date (Document No. 2);
WHEREAS Plaintiff filed a Motion to Remand, which will be opposed by Defendants, and is set for hearing on December 16, 2008 (Document 5);
WHEREAS the parties believe that the issues to be discussed at the Case Management Conference and the related case management deadlines may become moot if the Court grant's Plaintiff's Motion to Remand;
WHEREAS on September 18, 2008 Plaintiff and Defendants stipulated that Defendants shall have an extension of time to answer, move or otherwise plead in response to the First Amended Class Action Complaint until thirty (30) days after Plaintiffs' motion to remand is finally ruled upon (Document No. 3);
NOW, THEREFORE, based on the foregoing, the parties do hereby stipulate, by and through their counsel of record, to move the Case Management Conference from January 21, 2009 to March 25, 2009 at 3:00 p.m., that all related case management deadlines be reset in accordance therewith, and respectfully request that the Court issue an order reflecting same. The parties shall meet and confer prior to the conference and shall prepare a joint Case Management Conference Statement which shall be filed no later than ten (10) days prior to the Case Management Conference that complies with the Standing Order For All Judges Of The Northern District Of California and the Standing Order of this Court. Plaintiffs shall be responsible for filing the statement as well as for arranging the conference call. All parties shall be on the line and shall call (510) 637-3559 at the above indicated date and time.
DECHERT LLP Sarah Wager Attorneys for Defendants MOBILEFUNSTER, INC. and FUNMOBILE GAMES, INC.
Michael S. Doluisio (Admitted Pro Hac Vice) firstname.lastname@example.org Karen C. Daly (Admitted Pro Hac Vice) email@example.com Cira Center, 2929 Arch Street Philadelphia, PA 19104 Telephone: 215.994.4000 Facsimile: 215.994.2222
KAMBEREDELSON, LLC Alan Himmelfarb Attorneys for Plaintiff WENDI GUERRERO, individually and on behalf of a class of similarly situated individuals
GENERAL ORDER ATTESTATION
I, Sarah Wager, am the ECF user whose ID and password are being used to file this Stipulation to Continue Case Management Conference. In compliance with General Order 45, I hereby attest that Alan Himmelfarb of Kamberedelson, LLC have concurred in this filing.