Lindell et al v. Synthes USA et al
Filing
176
STIPULATION and ORDER re: Withdrawal of Plaintiff's Motion to Compel (Doc. 170): hearing of 2/20/2015 before Judge McAuliffe is OFF Calendar. signed by Magistrate Judge Barbara A. McAuliffe on 2/12/2015. (Herman, H)
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Catha Worthman (SBN 230399)
Kirsten Scott (SBN 253464)
Michael Caesar (SBN 280548)
LEWIS, FEINBERG, LEE, RENAKER &
JACKSON, P.C.
476 9th Street
Oakland, California 94607
Telephone: (510) 839-6824
Facsimile: (510) 839-7839
cworthman@lewisfeinberg.com
kscott@lewisfeinberg.com
mcaesar@lewisfeinberg.com
Charles Trudrung Taylor (SBN 127105)
Ana de Alba (SBN 253917)
LANG, RICHERT & PATCH
Fig Garden Financial Center
5200 North Palm Avenue, Fourth Floor
Fresno, California 93704
Telephone: (559) 228-6700
Facsimile: (559) 228-6727
ctt@lrplaw.net
ada@lrplaw.net
Counsel for Plaintiff and the Certified Classes
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
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TROY M. LINDELL, ON BEHALF OF HIMSELF
AND ALL OTHERS SIMILARLY SITUATED,
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Plaintiff,
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Case No. 1:11-CV-02053-LJO-BAM
STIPULATION AND ORDER RE:
WITHDRAWAL OF PLAINTIFF’S
MOTION TO COMPEL
vs.
Date:
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SYNTHES USA, SYNTHES USA SALES LLC,
SYNTHES SPINE COMPANY, LP,
Defendants.
February 20, 2015
Time:
9:00 a.m.
Courtroom 8
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STIPULATION AND PROPOSED ORDER
CASE NO. 1:11-CV-02053-LJO-BAM
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WHEREAS, on January 30, 2015, Plaintiff filed a Notice of Motion and Motion to Compel
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Pursuant to Local Rule 251 (ECF No. 170) seeking an order (1) compelling Defendants to respond in
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full to Requests for Production of Documents Nos. 1-3, which seek documents from Defendants
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setting forth the expense, deduction, and compensation policies that have affected Synthes Sales
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Consultants in California since 2007, and (2) compelling the appearance of Defendants’ designated
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representative(s) for a Rule 30(b)(6) deposition;
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WHEREAS, on February 6, 2015, the parties stipulated to the Court’s Informal Discovery
Dispute Resolution process;
WHEREAS, on February 6, 2015, the Court set a telephone conference call with the Court
for February 11, 2015, at 9:30 a.m., to address the pending discovery dispute;
WHEREAS, in meet and confer efforts the parties have resolved their current discovery
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disputes, while reserving rights, objections, and arguments that may be presented to the parties and
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to the Court in the future, by (1) the parties agreeing that the 30(b)(6) deposition shall take place on
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February 25, 2015, and (2) Defendants producing additional policy documents, and confirming that
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Defendants have now produced all policy documents setting forth the expense, deduction, and
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compensation policies that have affected Synthes Sales Consultants in California since 2007;
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IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel on
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behalf of the respective parties, that Plaintiff shall withdraw his pending Motion to Compel (ECF
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No. 170), and the matter shall be taken off calendar.
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DATED: February 11, 2015
BLANK ROME LLP
By: /s/ Anthony Haller
Anthony Haller
Attorneys for Defendants
SYNTHES USA, SYNTHES USA SALES LLC,
SYNTHES SPINE COMPANY, LP
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DATED: February 11, 2015
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LEWIS, FEINBERG, LEE, RENAKER & JACKSON,
P.C.
By: /s/ Kirsten Scott
Kirsten Scott
Attorneys for Plaintiffs
TROY M. LINDELL AND MARK POPE and the
Proposed Class
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ORDER
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IT IS SO ORDERED, pursuant to the parties’ Stipulation, Plaintiff’s Motion to Compel (ECF
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No. 170) shall be taken off calendar.
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Dated:
February 12, 2015
/s/ Barbara A. McAuliffe
UNITED STATES MAGISTRATE JUDGE
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