IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
January 28, 2011
THE ANSCHUTZ CORPORATION, PLAINTIFF,
MERRILL LYNCH & CO., INC.;
MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED; DEUTSCHE BANK SECURITIES INC.; MOODY'S INVESTORS SERVICE, INC.;
THE MCGRAW-HILL COMPANIES, INC.; FITCH, INC.;
AND FITCH RATINGS, LTD.,
The opinion of the court was delivered by: Judge: Hon. Susan Illston
Mark C. Hansen email@example.com David L. Schwarz (206257) firstname.lastname@example.org Kevin J. Miller (pro hac vice) email@example.com Andrew C. Shen (pro hac vice) firstname.lastname@example.org KELLOGG, HUBER, HANSEN, TODD, EVANS & FIGEL, P.L.L.C. 1615 M Street, N.W., Suite 400 Washington, D.C. 20036 Telephone: (202) 326-7900 Facsimile: (202) 326-7999 R. Alexander Saveri (173102) email@example.com Geoffrey C. Rushing (126910) firstname.lastname@example.org SAVERI & SAVERI, INC. 706 Sansome Street San Francisco, CA 94111-5619 Telephone: (415) 217-6810 Facsimile: (415) 217-6813 Attorneys for Plaintiff The Anschutz Corporation
JOINT REQUEST FOR A CONTINUANCE OF THE CASE MANAGEMENT CONFERENCE
Date: February 4, 2011 Time: 3:00 P.M.
DEMAND FOR JURY TRIAL
2011, at 3:00 p.m. or such earlier time on that date as the Court may have available scheduled December 14, 2010 as the default date for the CMC, provided that the Court had issued 6 a ruling on the Motions in advance of that date. On December 7, 2010, the parties stipulated to 7 continue the December 14, 2010 hearing date until February 4, 2011. As the Court knows, all 8 discovery in this case has been stayed pending this Court's rulings on Defendants' Motions to
The parties jointly submit this Request for a Continuance of the Case Management Conference (the "CMC"), currently scheduled for February 4, 2011 at 3:00 p.m., to March 11, 3
During the October 26, 2010 hearing on Defendants' Motions To Dismiss, the Court
Dismiss. In the Joint Case Management Statement filed on October 19, 2010 (DN 198), the 10 parties agreed to meet and confer within 10 business days of the Court's rulings on Defendants' 11
Motions To Dismiss, at which time the parties will engage in further discussions concerning the 12 disclosures required by Federal Rule of Civil Procedure 26(a)(1), any modifications to limits on 13 the number of interrogatories and depositions, and the development of a discovery plan in 14 accordance with Rule 26(f)(2)-(f)(3), including disclosure or discovery of electronically-stored information. In order to allow sufficient time for these meet and confer discussions prior to the 16
CMC be continued until March 11, 2011, or until such other time as the Court deems proper.
Counsel for many of the parties will be traveling from the East Coast and therefore respectfully request that, should the Court reschedule the CMC to March 11, the Court set the CMC for an earlier time on that date, if any such time is available.
CMC and to promote judicial efficiency and economy, the parties respectfully request that the
Counsel are informed that this Court has availability for the CMC at 3:00 p.m. on March 11. 19
GENERAL ORDER NO. 45 CERTIFICATION
I, Kevin J. Miller, hereby attest pursuant to Northern District of California General
Order No. 45 that the concurrence to the filing of this document has been obtained from each 4 signatory hereto. 5
Kevin J. Miller
AT R CT
ES DIST I
T N SO ORDERED
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