IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
September 15, 2010
KENNETH C. RUMP, RESPONDING PARTY,
PHILIPS LIFELINE, AN ENTITY; AND DOES 1- 50, INCLUSIVE, DEFENDANTS.
STIPULATION RE DUE DATE FOR AND FORMAT OF DEFENDANTS' OPPOSITION PAPERS TO PLAINTIFF'S MOTION FOR ORDER REOPENING DISCOVERY PROCEEDINGS
WHEREAS, under the Court's Standing Order of May 2006, parties seeking the Court's intervention in a discovery dispute shall submit the dispute to the Court for consideration via letter brief;
WHEREAS, the plaintiff in this action filed a noticed motion with the court for an order reopening discovery proceedings, said motion to be heard on October 5, 2010 at 9:00 a.m.;
WHEREAS, the undersigned parties desire to comply with the Court's Standing Order of May 2006;
NOW THEREFORE, KENNETH C. RUMP, the plaintiff in this action, ("Plaintiff") and LIFELINE SYSTEMS COMPANY and LIFELINE SYSTEMS, INC., the defendants, ("Defendants") stipulate and consent, in writing, as follows:
(1) Defendants shall file a response to Plaintiff's Motion for Order Reopening Discovery Proceedings no later than Friday, September 17, 2010 in the same format that Plaintiff utilized for his noticed motion;
(2) Plaintiff shall file no reply to Defendants' opposition papers;
(3) The Motion for Order Reopening Discovery Proceedings shall be submitted on the papers, and the hearing thereon scheduled for October 5, 2010 shall be vacated; and
(4) In the event that the Court determines that the issue requires oral argument, the parties hereto request that an alternate date for a conference be selected because counsel for Defendants has a prior commitment scheduled on October 5, 2010.
CERTIFICATE OF SERVICE
I am employed in the County of Contra Costa, State of California. I am over the age of eighteen years and not a party to the within case; my business address is: 2255 Morello Avenue, Suite 240, Pleasant Hill, California 94523. On this day I caused to be served the document(s) listed below:
Lifeline Systems Company represented by 30 _____________________________________________________________________________________________________________________
Thomas Michael McInerney Ogletree Deakins Nash Smoak & Stewart, P.C. Steuart Tower, Suite 1300 One Market Plaza San Francisco, CA 94105 415-442-4810 Fax: 415-442-4870 Email: firstname.lastname@example.org LEAD ATTORNEY ATTORNEY TO BE NOTICED Erica Kristen Rocush Ogletree Deakins Nash Smoak & Stewart Steuart Tower, Suite 1300 One Market Plaza San Francisco, CA 94105 (415) 442-4810 Fax: (415) 442-4870 Email: email@example.com ATTORNEY TO BE NOTICED
By emailing or electronically transmitting, based upon agreement of the parties to accept service by e-mail or electronic transmission, the documents to the person at the e-mail addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed on September 10, 2010 at Pleasant Hill, California.
Donna P. White
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