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Ambroff v. American Medical Systems

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO -- ECF PROGRAM


October 20, 2009

ELLEN AMBROFF AND TERRY AMBROFF, PLAINTIFFS,
v.
AMERICAN MEDICAL SYSTEMS, INC., AND DOES ONE THROUGH TWENTY-FIVE, 22 INCLUSIVE, 23 DEFENDANTS.

The opinion of the court was delivered by: James Larson United States Magistrate Judge

STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE MANAGEMENT AND PRETRIAL ORDER

DATED 06/29/2009

Civil L.R. 7-12

This Stipulation is entered into between Plaintiffs, Ellen Ambroff and Terry Ambroff, by and through their counsel of record, Hersh and Hersh, a professional corporation, and Defendant, Kenney & Markowitz American Medical Systems, Inc., by and through its counsel of record, Kenney & Markowitz, L.L.P. The parties stipulate as follows:

1. Based upon the parties Joint Case Management Statement and discussion at the June 24, 2009 Case Management Conference, on June 29, 2009, the Court entered its Case Management and Pretrial Order scheduling various dates in this matter.

2. During July, 2009, the Court's clerk contacted counsel for AMS to inform them that the date chosen as the last day to hear dispositive motions was not suitable and that parties should stipulate to another date. The Court suggested September 30, 2010 as the last day to hear dispositive motions.

3. The parties stipulate and respectfully request that the Court order September 30, 2010 as the last day to hear dispositive motions and incorporate that date into the existing Case Management and Pretrial Order dated June 29, 2009.

Respectfully submitted,

DATED: October 19, 2009

KENNEY & MARKOWITZ L.L.P KEN M. MARKOWITZ SAMANTHA D. HILTON Attorneys for Defendant AMERICAN MEDICAL SYSTEMS INC.

HERSH AND HERSH AMY ESKIN Attorney for Plaintiff ELLEN AND TERRY AMBROFF

[PROPOSED] ORDER

Pursuant to the parties' stipulation, the last day for the Court to hear dispositive motions in this action is September 30, 2010.

IT IS SO ORDERED.

20091020

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