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Re: None

Wednesday, 06/13/2007 12:11:29 PM

Wednesday, June 13, 2007 12:11:29 PM

Post# of 157299
Class action Lawsuit updated yesterday.

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
Case No. 06-21071-CIV-ALTONAGA/Turnoff
RICHARD STEVENS, et al., on behalf of
themselves and all others similarly situated,
Plaintiffs, v. GLOBETEL COMMUNICATIONS CORP., et al.,Defendants.

JOINT MOTION TO
SET MEDIATION SCHEDULE AND STAY PROCEEDINGS
Pursuant to the Court’s Order, dated May 10, 2007, Plaintiffs and Defendants jointly move to set a mediation schedule and stay all proceedings until September 10, 2007. In support of this motion, the parties state as follows:

1. On May 10, 2007, the Court issued an Order Setting Trial and Pre-trial Schedule, Requiring Mediation, and Referring Certain Motions to Magistrate Judge (the “Scheduling Order”);

2. The Scheduling Order directed the parties to select a mediator and a time and place for the mediation to take place, as well as to jointly file, by June 11, 2007, a proposed order scheduling mediation.

3. The parties have conferred regarding the Scheduling Order and have selected retired Judge Nicholas H. Politan as a mediator. The parties are presently coordinating among themselves, Judge Politan and counsel for Defendants’ insurance carrier, to schedule the mediation to occur in Case 1:06-cv-21071-CMA Document 68-1 Entered on FLSD Docket 1 Also participating in the mediation will be counsel for plaintiff in the currently stayed shareholder derivative action brought nominally on behalf of GlobeTel. See Stockton v.Dumas et al., 06-60923-CIV (stayed pursuant to Order On Joint Motion For An Order Staying Action, dated September 1, 2006 [Docket No. 15]). New York City between August 15, 2007 and August 31, 2007. The parties are hopeful that they will settle the case at mediation. Pursuant to the Scheduling Order, the parties will file a mediation report with the Court within five (5) days of the mediation.

4. In order to conserve resources and promote a resolution of this action by allowing the parties to focus their attention on the mediation, the parties request that this action be stayed until September 10, 2007, with all dates in the Scheduling Order tolled until that time.

WHEREFORE, the parties respectfully request that they mediate the claims asserted herein with Judge Politan and stay all proceedings until September 10, 2007. A proposed order reflecting the foregoing is submitted herewith.

Dated: June 11, 2007 Respectfully submitted,
VIANALE & VIANALE LLP
/s/ Julie P. Vianale
Kenneth Vianale (FBN 0169688)
Julie P. Vianale (FBN 0184977)
2499 Glades Road, Suite 112
Boca Raton, Florida 33431
Tel: 561-392-4750
Plaintiffs’ Liaison Counsel

SHALOV STONE BONNER & ROCCO LLP
Lee Shalov
Thomas G. Ciarlone, Jr.
485 Seventh Avenue, Suite 1000
New York, NY 10018
Tel: 212-239-4340

SARRAF GENTILE LLP
Ronen Sarraf
Joseph Gentile
485 Seventh Avenue, Suite 1005
New York, NY 10018
Tel: 212-868-3610

Plaintiffs’ Co-Lead Counsel

GUNSTER, YOAKLEY & STEWART, P.A.
/s/ John F. Mariani (w/ consent)
John F. Mariani (FBN: 263524)
Phillips Point - Suite 500 East
777 South Flagler Drive
West Palm Beach, FL 33401-6194
Tel: 561-650-0600

GOODWIN PROCTER LLP
Brian E. Pastuszenski
Alexis L. Shapiro
53 State Street Exchange Place
Boston, MA 02109
Tel: 617-570-1000

Counsel for Defendants GlobeTel
Communications Corp. and Timothy Huff

Area's Bold and underlined I added. WilliamFL

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