The opinion of the court was delivered by: Honorable Patricia V. Trumbull
STIPULATION AND [PROPOSED] ORDER HEARING THE MOTION FOR 17 SHORTENING TIME FOR PROTECTIVE ORDER REGARDING DEPOSITIONS
WHEREAS, concurrently with filing this Stipulation, defendant Juniper Networks, Inc. and non-parties Jodi Sutton, Ann Laporte and Ray Martinelli will file a Motion for Protective Order Regarding Depositions ("Motion for Protective Order");
WHEREAS, the issue raised in the Motion for Protective Order is discrete and the parties would like to have it heard on the same date as the previously-scheduled hearing on Lead Plaintiffs' pending Motion to Compel Juniper Networks, Inc. to Produce Restatement Communications (Dkt. No. 280 in Case No. 06-04327);
WHEREAS, in addition, the Motion for Protective Order concerns certain depositions that the lead plaintiffs plan to take in August, and the parties need a decision on the Motion for Protective Order sooner than the standard 35-day notice so they can adequately plan in advance of the planned depositions;
NOW THEREFORE, the parties stipulate, and request that the Court order:
1. Any opposition(s) to the Motion for Protective Order shall be filed by July 22, 2009;
2. Any reply in support of the Motion for Protective Order shall be filed by July 28, 2009;
3. A hearing on the Motion for Protective Order shall be held on August 4, 2009 at 10:00 a.m.
WILSON SONSINI GOODRICH & ROSATI, P.C. NINA F. LOCKER STEVEN GUGGENHEIM JONI OSTLER 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: 650/493-9300 650/493-6811 (fax) Counsel for Defendant Juniper Networks, Inc., and Non-Party Witnesses Jodi Sutton, Anne Laporte and Ray Martinelli
BARBARA J. HART DAVID C. HARRISON LOWEY DANNENBERG COHEN & HART, P.C. DAVID C. HARRISON One North Broadway, 5th Floor White Plains, NY 10601-2310 914-733-7228 (telephone) ...