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Universal Operations Risk v. Global Rescue LLC

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


December 27, 2011

UNIVERSAL OPERATIONS RISK
MANAGEMENT, LLC, EDWARD MUHLNER, THOMAS BOCHNOWSKI,
AND MARK COHON,
PLAINTIFFS,
v.
GLOBAL RESCUE LLC, AND DOES 1 THROUGH 10, INCLUSIVE,
DEFENDANTS.

The opinion of the court was delivered by: Judge: Honorable Saundra B. Armstrong

GREENBERG TRAURIG, LLP 1 TODD R. WULFFSON (SBN 150377) 3161 Michelson Drive, Suite 1000 Irvine, California 92612 T: (949) 732-6500 3 F: (949) 732-6501 Wulffsont@gtlaw.com 4 5 VALDEZ SEYEDIN-NOOR DUNSON & DOYLE LLP AMY K. TODD (SBN 208581) 6 116 New Montgomery Street, Suite 210 San Francisco, CA 94105 7 T: (415) 202-5950 8 F: (415) 202-5951 atoddgher@vsnlaw.com 9

JOINT STIPULATION AND xxxxxxxxxxx PROPOSED ORDER TO EXTEND TIME TO RESPOND TO DEFENDANT'S NOTICE OF MOTION, MOTION AND AMENDED MEMORANDUM IN SUPPORT OF GLOBAL RESCUE LLC'S 16 MOTION TO DISMISS, TRANSFER, OR STAY

Date: April 10, 2012

Time: 1:00 p.m.

Place: Courtroom 1

TO THE HONORABLE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

WHEREAS, Plaintiffs served their First Amended Complaint in this matter on November 8, 2011; 5

WHEREAS, Defendants filed their Notice of Removal in this Court on December 5, 2011;

WHEREAS, Defendant filed its Motion to Dismiss, Transfer, or Stay before Magistrate Judge Donna M. Ryu on December 12, 2011; 8

WHEREAS, this action, Universal Operations Risk Management, LLC et al. v. Global Rescue LLC et al., Case No. 11-CV-05969, was reassigned to the Honorable Saundra B. Armstrong for all 10 further proceedings on December 13, 2011; 11

WHEREAS, per the December 13, 2011 Reassignment Order from the Office of the Clerk of Court, Defendant filed its Re-Notice of Motion, Motion and Amended Memorandum in Support of 13

B. Armstrong on December 16, 2011; 15

WHEREAS, there have been no prior requests to extend any deadlines and such a request is 17 made: (1) to remove any arguable requirement for Plaintiffs to respond in a California court in violation 18 of the Temporary Restraining Order issued by the Superior Court of the Commonwealth of Massachusetts, Suffolk, Case No. 11-4502G (and which action has subsequently been removed to and is 20 pending before the U.S. District court for the District of Massachusetts, No. 1:11-civ-12250 (Wolf, 21 C.J.)), which currently prohibits Plaintiffs Muhlner, Bochnowski and Cohon from prosecuting their 22 claims, prosecuting a separate suit, or obtaining relief in any other court except a Massachusetts state or 23 federal court, and specifically prohibits them from prosecuting a separate suit in any state and federal 24 court of California; (2) based on Plaintiffs' counsel's request to alleviate any requirement that Plaintiffs' 25 counsel brief and respond to Defendant's Motion during the upcoming holidays, including during pre-26 scheduled holiday vacation time with family, and; (3) for good cause and not for any purposes of delay 27 on either party's part. 28

Global rescue LLC's Motion to Dismiss, Transfer, or Stay ("the Motion") before the Honorable Saundra 14

WHEREAS, the Court's first available hearing date is April 10, 2012;

It is therefore agreed to and stipulated by and between the parties and their respective counsel 2 that an extension of deadlines is warranted and the revised schedule shall be as follows: 3

1. Opposition to Defendant's Re-Notice of Motion re Motion to Dismiss, Transfer or Stay is due January 24, 2012. 5

2. Reply to Plaintiffs' Opposition to Defendant's Re-Notice of Motion re Motion to Dismiss, Transfer or Stay is due January 31, 2012. 7

Stipulated By and Between:

PURSUANT TO THE PARTIES' STIPULATION, IT IS SO ORDERED.

The Honorable Saundra B. Armstrong United States District Judge

20111227

© 1992-2011 VersusLaw Inc.



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