The opinion of the court was delivered by: Honorable Jeremy Fogel Judge of the U.S. District Court
STIPULATION AND [PROPOSED] ORDER TO CONTINUE MOTION TO DISMISS HEARING AND CASE MANAGEMENT CONFERENCE
This Document Relates To: ALL ACTIONS.
WHEREAS, the hearing on Defendants' Motions to Dismiss and a Case Management Conference are currently scheduled for March 13, 2009;
WHEREAS, due to scheduling conflicts, the current settlement discussions, and the Parties' focus thereon, Lead Plaintiffs have requested and Defendants have consented to continue the hearing on Defendants' Motions to Dismiss and the Case Management Conference to a later date;
WHEREAS, the Parties understand that April 24, 2009 is available on the Court's calendar;
WHEREAS, subject to the Court's approval, the parties stipulate as follows:
1) The hearing on Defendants' Motions to Dismiss currently scheduled for March 13, 2009 shall be rescheduled to April 24, 2009.
2) The Case Management Conference currently scheduled for March 13, 2009 shall be rescheduled to April 24, 2009.
3) By executing this Stipulation, the parties have not waived and expressly retain all claims, defenses and arguments whether procedural, substantive or otherwise. This Stipulation is without prejudice to any subsequent motion to stay this action, or any objections or defenses thereto, and this Order is entered without prejudice to the rights of any party to apply for a modification of this Order.
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