STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
WHEREAS on September 18, 2008 defendants Mobilefunster, Inc. and Funmobile Games, Inc. ("Funmobile 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 27, 2009 at 10:00 a.m., and related case management deadlines flowing from that date (Document No. 3);
WHEREAS Plaintiff filed a Motion to Remand, which will be opposed by the Funmobile Defendants, and is set for hearing on December 16, 2008 (Document No. 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 October 27, 2008 Plaintiff, and defendant Cello Partnership, LLC d/b/a/ Verizon Wireless ("Verizon Wireless") stipulated that the time for Verizon Wireless to plead or otherwise respond to the complaint would be extended to January 19, 2009 (Document No. 6); and
WHEREAS on October 29, 2008 Plaintiff and the Funmobile Defendants stipulated that the Funmobile 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. 10);
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 27, 2008 to March 24, 2008 at 10:00 a.m., that all related case management deadlines be reset in accordance therewith, and respectfully request that the Court enter an order reflecting same.
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 David Parisi of Parisi & Havens and Geoffrey Graber of Morrison & Foerster have concurred in this filing.
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