pR~GINAt

FILM IN CLERK'S OffIOE

U .S .D .C . - Atlanta

/"

MAR 5 - 2004
IN THE UNITED STATES DISTRICT COURIlUTHE~,
FOR THE NORTHERN DISTRICT OF GEORC8#A
`
ATLANTA DIVISION
JOHN RAMSEY, PATSY RAMSEY and
BURK.E RAMSEY, a minor, by his
next friends and natural parents,
JOHN RAMSEY and PATSY RAMSEY, .
Plaintiffs,

Clark
~jury Clerk

CASE NO. : 1 03 CV-3976 (TWT)

vs

FOX NEWS NETWORK, L .L .C ., d/b/a

Fox News Channel,
Defendant .
STIPULATION FOR EXTENSION OF TIME
WHEREAS plaintiffs John Ramsey, Patsy Ramsey and Burke Ramsey
("Plaintiffs") filed their initial Complaint on or about December 23, 2003 and served
it pursuant to Rule 4 of the Federal Rules of Civil Procedure by sending a Waiver
of Service;
WHEREAS counsel for defendant Fox News Network, LLC ("Fox News
Channel") signed the Waiver of Service, thus setting a deadline of February 23,
2004 for the Fox News Channel to respond to the Complaint;
WHEREAS Plaintiffs filed and served by mail their Amended Complaint on
or about February 17, 2004, thus extending Fox News Channel's rime to respond
until March 5, 2004;

~- 969051W 75 . 830249 v I

\_

WHEREAS Fox News Channel filed and served by hand a motion to transfer
venue on February 19, 2004, thus requiring any opposition to be filed by PlaintitTs by
March 4, 2004 ;
WHEREAS the parties have filed a March 3, 2004 stipulation agreeing to
extend the time each party has to respond to the motion to transfer venue and the
Amended Complaint as follows:
Plaintiffs shall file and serve any opposition to the motion to transfer
venue no later than March 31, 2004;
Fox News Channel shall file and serve any reply to Plaintiffs'
opposition to the motion to transfer venue no later than April 23, 2004;
"

Fox News Channel shall file and serve its response to Plaintiffs'
Amended Complaint no later than April 28, 2004 ;
Plaintiffs shall file and serve their opposition to any motion to dismiss
by Fox News Channel no later than May 28, 2004; and
Fox News Channel shall file and serve any reply to Plaintiffs'
opposition to any motion to dismiss no later than June 18, 2004;

WHEREAS the parties have agree that Fox News Channel's filing of the
motion to transfer venue should not be interpreted as an "appearance" for purposes
of Local Rules 16.1, 16.2 and 3 .3, and Federal Rule of Civil Procedure 26
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(Fed .R .Civ .Proc.), and therefore agree that the time limits prescribed in those rules
are not triggered;
IT IS HEREBY stipulated and agreed by the undersigned counsel for the
parties as follows:
"

The lead attorneys for both parties will convene an in-person conference
pursuant to Fed.R .Civ.Proa 26(f) and Northern District of Georgia
Local Rule 16.1 on or before May 14, 2004, which is 16 days after Fox
News Channel's deadline to respond to Plaintiffs' Amended Complaint;

"

The parties will submit a Joint Preliminary Report and Discovery Plan
pursuant to Northern District of Georgia Local Rule 16 .2 on or before
May 28, 2004, which is 30 days after Fox News Channel's deadline to
respond to Plaintiffs' Amended Complaint;

"

The parties will submit a Joint Certificate of Interested Persons pursuant

to Northern District of Georgia Local Rule 33A on or before May 28,
2004, which is 30 days after Fox News Channel's deadline to respond to
Plaintiff's' Amended Complaint; and

"

Fox News Channel and the Plaintiffs will each submit Initial
Disclosures pursuant to Fed.R .Civ.Proc. 26(a)(1) on or before May 28,

3
tiWY - 9fi70L00)3 . 810'49 VI

2004, which is 30 days after Fox News Chaiuiel's deadline to respond to

Plaintiffs' Amended Complaint.
SO ORDERED this

day of March, 2004.

Judge, United States District Court,

Northern District of Georgia
CONSENTED TO :

CONSENTED TO:

L. LIN WOOD, P .C .

HOGAN & HARTSON

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~~~C(~1SlM~
Wood
i~, n
Georgia Bar No. 774588
Katherine M. Ventulett
Georgia Bar No. 727027

The Equitable Building

Suite 2140
100 Peachtree Street
Atlanta, Georgia 30303
Telephone: 404-522-1713
Telecopier : 404-522-1716
Counsel for Plaintiffs

Do
Hanswirth
Jas P . Conti
875 Third Avenue
New York, New York 10022
Telephone : 212-918-3000
Telecopier: 212-918-3100
Judson Graves
Georgia Bar No . 305700
Jennifer (Jenna) Moore
Georgia Bar No . 519729
ALSTON & BIRD LLP
One Atlantic Center
1201 West Peachtree Street
Atlanta, Georgia 30309-3424
Telephone : 404-881-7000
Telecopier: 404-881-7777
Counsel for Defendant

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