Barbosa v. Cargill Meat Solutions Corp.

Filing 34

STIPULATION and ORDER EXTENDING Discovery Deadline and Class Certification Motion Schedule by Two Months. Fact discovery deadline shall be February 7, 2013; Motion for class certification shall be filed by March 28, 2013; Oppositions to the m otion for class certification shall be filed by April 25, 2013; Any reply brief in support of the motion for class certification shall filed by May 10, 2013; and the motion for class certification shall be heard no later than June 3, 2013. Order signed by Magistrate Judge Sheila K. Oberto on 7/11/2012. (Timken, A)

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MECKLER BULGER TILSON MARICK &
PEARSON LLP
Joseph E. Tilson (admitted pro hac vice)
Jeremy J. Glenn (admitted pro hac vice)
Jason E. Barsanti (Cal Bar No. 235807)
123 North Wacker Drive, Suite 1800
Chicago, IL 60606
Tel: [phone] / Fax: [phone]
BENT CARYL & KROLL, LLP
Jesse M. Caryl (Cal Bar No. 208687)
6300 Wilshire Blvd., Suite 1415
Los Angeles, CA 90048
Tel: [phone] / Fax: [phone]
Attorneys for Defendant
CARGILL MEAT SOLUTIONS CORP.

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CHRISTINA BARBOSA and PATRICIA
AGUILLERA BARRIOS, on behalf of
themselves and all similarly situated individuals,

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Plaintiffs,

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THE DOWNEY LAW FIRM, LLC
Philip A. Downey, Esq. (pro hac vice)
Pennsylvania Bar ID No. 81603
P.O. Box 1021
Unionville, PA 19375
Tel: [phone] / Fax: [phone]

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION

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Daniel Patrick Hunt, Attorney at Law
PO Box 3040
South Pasadena, CA 91031
Tel: [phone]

Attorneys for Plaintiffs
CHRISTINA BARBOSA and PATRICIA
AGUILLERA BARRIOS

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R. REX PARRIS LAW FIRM
Alexander R. Wheeler
Kitty Kit Yee Szeto
43364 10th Street West
Lancaster, CA 93534
Tel: [phone] Fax: [phone]

v.
CARGILL MEAT SOLUTIONS CORP., and
DOES 1-50,
Defendants.

Case No. 1:11-cv-00275-LJO-SKO
Hon. Sheila K. Oberto
STIPULATION TO EXTEND
DISCOVERY DEADLINE AND
CLASS CERTIFICATION MOTION
SCHEDULE BY TWO MONTHS AND
ORDER
Complaint Filed: February 16, 2011
Trial Date: Not Set

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WHEREAS Plaintiffs and Defendant have engaged in written discovery and have worked
together to schedule depositions in this action;
WHEREAS the parties have engaged a private mediator to assist them with settlement

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discussions, having met for a full-day mediation on June 6, 2012 and having thereafter agreed to

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narrow and limit the scope of additional fact discovery before continuing the mediation, and

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counsel wish to stipulate to extend the discovery cut-off date and class certification motion

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schedule to allow them to complete such discovery and fully explore such mediation;
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STIPULATION TO EXTEND DISCOVERY DEADLINE AND CLASS CERTIFICATION MOTION SCHEDULE BY TWO MONTHS

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WHEREAS, pursuant to this Court’s Scheduling Order (Dkt. No. 26), the fact discovery

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cut-off date in this case is currently December 7, 2012; the motion for class certification is to be

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filed by January 28, 2013, any opposition filed by February 25, 2013, any reply briefs filed by

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March 11, 2013 and the motion for class certification to be heard by no later than April 3, 2013;

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WHEREAS, to allow the parties to complete the agreed upon discovery and fully explore

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settlement through mediation, subject to an order from this Court allowing the requested

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extensions of time, the parties desire to extend the fact discovery deadline and the other dates

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listed above by two months as follows:

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1.

Fact discovery deadline shall be February 7, 2013;

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2.

Motion for class certification shall be filed by March 28, 2013;

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3.

Oppositions to the motion for class certification shall be filed by April 25, 2013;

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4.

Any reply brief in support of the motion for class certification shall filed by May

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10, 2013; and

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5.

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SO STIPULATED.

The motion for class certification shall be heard no later than June 3, 2013.
R. REX PARRIS LAW FIRM
THE DOWNEY LAW FIRM, LLC

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DATED: July 9, 2012

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s/ Daniel Patrick Hunt
Attorneys for Plaintiffs
CHRISTINA BARBOSA and PATRICIA
AGUILLERA BARRIOS
MECKLER BULGER TILSON MARICK &
PEARSON LLP

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DATED: July 10, 2012

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s/ Jason E. Barsanti
Attorneys for Defendant
CARGILL MEAT SOLUTIONS CORP.

IT IS SO ORDERED.

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Dated:

July 11, 2012

/s/ Sheila K. Oberto

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UNITED STATES MAGISTRATE JUDGE

DEAC_Signature-END:

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STIPULATION TO EXTEND DISCOVERY DEADLINE AND CLASS CERTIFICATION MOTION SCHEDULE BY TWO MONTHS