IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
August 30, 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
STIPULATION AND [PROPOSED] ORDER RESCHEDULING CASE MANAGEMENT CONFERENCE Date: September 2, 2011
Time: 3:00 p.m. Ctrm: 10
DEMAND FOR JURY TRIAL
WHEREAS, on June 10, 2011, this Court issued an Order setting a Case Management Conference ("CMC") for September 2, 2011 at 3:00 p.m.; and 3 WHEREAS, counsel for Plaintiff has a scheduling conflict with the September 2, 2011 4 date; and 5 WHEREAS, the parties are in the process of meeting and conferring about several 6 outstanding discovery issues, and a continuance until September 16, 2011 will give the parties 7 further time to try to narrow those issues and provide this Court an opportunity to consider prior 8 to the CMC any statements the parties file regarding remaining unresolved discovery issues; and 9
WHEREAS, Plaintiff has conferred with Defendants and all parties have agreed to 10 reschedule the CMC to September 16, 2011 at 2:30 p.m.; 11 IT IS THEREFORE STIPULATED AND AGREED, by all parties, acting through their 12 respective counsel, subject to this Court's approval, that the CMC shall be rescheduled for 13 September 16, 2011 at 2:30 p.m. 14 15
PURSUANT TO STIPULATION, AND FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. Dated: _____________, 20__
Hon. Susan Illston United States District Judge
Dated: August 26, 2011 Respectfully submitted, 2 By: /s/ Kevin J. Miller 3 Mark C. Hansen David L. Schwarz (206257) 4 Kevin J. Miller (pro hac vice) Andrew C. Shen (pro hac vice) 5 KELLOGG, HUBER, HANSEN, TODD, EVANS & FIGEL, P.L.L.C. 6 1615 M Street, N.W., Suite 400 Washington, D.C. 20036 7 Attorneys for The Anschutz Corporation 8 By: /s/ David T. Biderman 9 10 David T. Biderman Philip A. Leider Jonmi N. Koo 11 PERKINS COIE LLP Four Embarcadero Center, Suite 2400 12 San Francisco, CA 94111 Attorneys for The McGraw-Hill Companies, Inc.
By: /s/ Elizabeth A. Frohlich Elizabeth A. Frohlich MORGAN, LEWIS & BOCKIUS One Market Street Spear Street Tower San Francisco, CA 94105 Attorney for Deutsche Bank Securities Inc. 20 By: /s/ Roberta A. Kaplan 21 Roberta A. Kaplan PAUL, WEISS, RIFKIND, WHARTON & 22 GARRISON LLP 1285 Avenue of the Americas 23 New York, New York 10019 24 Attorney for Fitch, Inc. and Fitch Ratings, Ltd.
GENERAL ORDER 45 CERTIFICATION
I, Kevin J. Miller, hereby attest pursuant to N.D. Cal. General Order 45 that the 3 concurrence to the filing of this document has been obtained from each signatory hereto. 4 5
Dated: August 26, 2011 KELLOGG, HUBER, HANSEN, TODD, EVANS & FIGEL, P.L.L.C. By: /s/ Kevin J. Miller Kevin J. Miller Attorney for The Anschutz Corporation
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