Free Renotice motion hearing - District Court of California - California

Case 4:08-cv-01849-SBA

Document 15

Filed 06/18/2008

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Mitchell F. Boomer (State Bar No. 121441) Janine R. Hudson (State BarNo. 206671) JACKSON LEWIS LLP 199 Fremont Street, 10th Floor San Francisco, California 94105 Telephone: (415) 394-9400 Facsimile: (415) 394-9401 Attorneys for Defendant PFIZER, INC.

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION

10 11 12 13 14 15 16 17 18 _________________ 19 20 21 22 23 24 25 26 27 28 PLEASE TAKE NOTICE that on July 29, 2008 at 1:00 p.m. or as soon thereafter as the motion may be heard in Courtroom 3 of the above-entitled Court, located at 1301 Clay Street, Suite 400 S, Oakland, CA 94612-5212, Defendant PFIZER, INC. ("Pfizer") will and hereby does move the Court for an order transferring the above-captioned action from the Northern District of California to the Southern District of New York pursuant to 28 U.S.C. §1404(a). brought this motion on the grounds that the circumstances Pfizer has Defendants. Date: Time: Ctrm.: DJ: July 29, 2008 1:00 p.m. 3, 3rd Floor Hon. Saundra B. Armstrong vs. PFIZER, INC., a Delaware corporation; and DOES 1 through 40, inclusive, RANDALL 1. SLOAN, an individual, Plaintiff, Case No. CV-08-1849 SBA DEFENDANT PFIZER, INC.'S RENOTICE OF MOTION AND MOTION TO TRANSFER VENUE [28 U.S.c. § 1404(a)]; MEET-ANDCONFER CERTICATION; AND SUPPORTING DOCUMENTS

Case Removed to Federal Court: 4/7/2008 ---' Case Reassigned: 06/17/2008

of this case require that trial be

conducted in the Southern District of New York for the convenience of the parties and witnesses, and in the interests of justice. This motion is based upon the Notice of Motion and Memorandum
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of Points and

DEF PFIZER, INC.' S RENOTICE OF MOTION AND MOTION TO TRANSFER VENUE [28 U.S.C. § 1404(a)]; M&C CERT.; AND SUPP. DOCS. Case No. CV-08-1849 SBA

Case 4:08-cv-01849-SBA

Document 15

Filed 06/18/2008

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Authorities in Support of hereof, the Declaration of Lynne Buongiorno, the Request for Judicial Notice, as well as any other papers or evidence that may properly come before this Court. MEET -AND-CONFER CERTIFICATION I hereby certify that on June 18, 2008, I telephoned Plaintiff s counsel Daniel P. lannitelli to discuss Pfizer's motion to transfer and proposed hearing date, thereby fulfilling the meet-andconfer requirement 6/16/08). Dated: June 18, 2008 Respectfully submitted, JACKSON LEWIS LLP set forth in Judge Armstrong's Standing Order for Civil Cases (revised

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By:

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Isl Janine R. Hudson Mitchell F. Boomer Janine R. Hudson Attorneys for Defendant PFIZER, INC.

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DEF PFIZER, INC.' S RENOTICE OF MOTION AND MOTION TO TRANSFER VENUE [28 U.S.C. § 1404(a)]; M&C CERT.; AND SUPP. DOCS. Case No. CV-08-1849 SBA