Corra v. Energizer Holdings Inc., et al

Filing 79

STIPULATION and ORDER to Further Extend Discovery and Briefing Schedules. Last Day for Defendants to Respond to Plaintiff's First Set of Requests for Admissions, First Set of Requests for Productions, and First Set of Interrogatories is 10/10/2014. Mid-Discovery Status Report due by no later than 10/23/2014. Mid-Discovery Status Conference set for 10/30/2014, at 10:30 AM in Courtroom 7 (SKO) before Magistrate Judge Sheila K. Oberto. Deadline for Class Discovery is 11/7/201 4. Last day for filing Class Certification Motion is 12/5/2014. Last day for Plaintiff to produce and for Defendants to depose class certification experts is 1/5/2015. Last day for filing Opposition to Class Certification Motion is 1/19/2015. Las t day for Defendants to produce and for Plaintiff to depose class certification experts is 2/20/2015. Last day for filing Reply to Class Certification Opposition is 4/3/2015. Class Certification Hearing is set for 5/11/2015, at 01:30 PM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii. Order signed by Magistrate Judge Sheila K. Oberto on 8/5/2014. (Timken, A)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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AIDA CORRAL, On Behalf of Herself and
All Others Similarly Situated,
Plaintiff,

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CASE NO. 1:12−CV−01736−AWI−SKO
STIPULATION TO FURTHER EXTEND
DISCOVERY AND BRIEFING SCHEDULES

v.

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Corporation; PLAYTEX
PRODUCTS, LLC, fka PLAYTEX
PRODUCTS, INC, a Delaware Corporation;
SUN PHARMACEUTICALS, LLC, a
Delaware Limited Liability Company,
Defendants.

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Plaintiff Aida Corral and Defendants Energizer Holdings, Inc., Playtex Products, Inc. and

19 Sun Pharmaceuticals, LLC (“Defendants”) (collectively, the “Parties”) jointly stipulate to extend
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the discovery and briefing schedules in this action.

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WHEREAS, on February 3, 2014, the Parties filed a Stipulation and Proposed Order to

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Extend Discovery and Briefing Schedules (ECF #70) proposing discovery and briefing schedules

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to the Court that would permit the parties additional time during which they could explore

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whether the case could be settled;

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WHEREAS, on February 5, 2014, the Court issued a Scheduling Order (ECF # 71)
resetting the discovery and briefing schedules;
WHEREAS, on April 15, 2014, the Parties filed a Stipulation and Proposed Order (ECF

28 #72) to further extend the discovery and briefing schedules as the Parties continued to engage in
STIPULATION TO FURTHER EXTEND
DISCOVERY AND BRIEFING SCHEDULES

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settlement negotiations;
WHEREAS, on April 22, 2014 the Court issued a Scheduling Order (ECF #74) resetting
the discovery and briefing schedules;

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WHEREAS, on May 29, 2014, the Parties filed a Stipulation and Proposed Order (ECF
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#75) to once again extend the discovery and briefing schedules as the Parties continued to further
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engage in settlement negotiations;
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WHEREAS, on June 3, 2014 the Court issued a Scheduling Order (ECF #76) resetting
the discovery and briefing schedules as follows;
Event

Deadline

Last Day for Defendants to Respond to Plaintiff’s First
Set of Requests for Admissions, First Set of Requests
for Productions, and First Set of Interrogatories

August 26, 2014

Mid-Discovery Status Report

September 11, 2014

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Mid-Discovery Status Conference

September 18, 2014 at10:00 a.m.

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Deadline for Class Discovery

September 23, 2014

Last day for filing Class Certification Motion. Plaintiff
shall simultaneously provide class expert report(s) with
the motion and make expert(s) available for deposition
thereafter.

October 21, 2014

Last day for Plaintiff to produce and for Defendants to
depose class certification experts, if any, identified in
Plaintiff's Class Certification Motion.

November 21, 2014

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Last day for filing Opposition to Class Certification
Motion. Defendants shall simultaneously provide class
expert report(s) with opposition and make expert(s)
available for deposition thereafter.

December 5, 2014

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January 6, 2014

Last day for filing Reply to Class Certification
Opposition

February 17, 2015

Class Certification Hearing

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Last day for Defendants to produce and for Plaintiff to
depose class certification experts, if any, identified in
Defendants' Class Certification Opposition.

March 23, 2015 at 1:30 p.m.

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WHEREAS, the Parties are continuing with their efforts to finalize a settlement and are
in the process of negotiating a written settlement agreement;
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STIPULATION TO FURTHER EXTEND
DISCOVERY AND BRIEFING SCHEDULES

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IT IS HEREBY STIPULATED by the Parties, by and through their counsel of record
herein, as follows:
1. The above-referenced discovery and briefing schedules shall be vacated; and
2. The discovery and briefing schedules shall be as follows:
Deadline

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Event
Last Day for Defendants to Respond to Plaintiff’s First
Set of Requests for Admissions, First Set of Requests
for Productions, and First Set of Interrogatories

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Mid-Discovery Status Report

October 26, 2014

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Mid-Discovery Status Conference

November 3, 2014 at 10:00 a.m.

Deadline for Class Discovery

November 7, 2014

Last day for filing Class Certification Motion. Plaintiff
shall simultaneously provide class expert report(s) with
the motion and make expert(s) available for deposition
thereafter.

December 5, 2014

Last day for Plaintiff to produce and for Defendants to
depose class certification experts, if any, identified in
Plaintiff's Class Certification Motion.

January 5, 2015

Last day for filing Opposition to Class Certification
Motion. Defendants shall simultaneously provide class
expert report(s) with opposition and make expert(s)
available for deposition thereafter.

January 19, 2015

Last day for Defendants to produce and for Plaintiff to
depose class certification experts, if any, identified in
Defendants' Class Certification Opposition.

February 20, 2015

Last day for filing Reply to Class Certification
Opposition

April 3, 2015

Class Certification Hearing

May 7, 2015 at 1:30 p.m.

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October 10, 2014

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Dated: July 31, 2014
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LATHAM & WATKINS LLP
Daniel Scott Schecter
Michael J. Reiss
By

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/s/ Michael J. Reiss
Michael J. Reiss
Attorneys for Defendants
Energizer Holdings, Inc.

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STIPULATION TO FURTHER EXTEND
DISCOVERY AND BRIEFING SCHEDULES

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BONNETT, FAIRBOURN, FRIEDMAN &
BALINT, P.C.
Patricia N. Syverson

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By

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/s/ Patricia N. Syverson
Patricia N. Syverson
Attorneys for Plaintiff
Aida Corral

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STIPULATION TO FURTHER EXTEND
DISCOVERY AND BRIEFING SCHEDULES

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ORDER

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Pursuant to the parties’ Stipulation, for good cause shown and to allow the parties an

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opportunity to finalize their settlement discussions, the discovery and briefing schedule in this

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matter is AMENDED as follows:

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Event

Deadline

Last Day for Defendants to Respond to Plaintiff’s First
Set of Requests for Admissions, First Set of Requests
for Productions, and First Set of Interrogatories

October 10, 2014

Mid-Discovery Status Report

October 23, 2014

Mid-Discovery Status Conference

October 30, 2014 at 10:30 a.m.

Deadline for Class Discovery

November 7, 2014

Last day for filing Class Certification Motion. Plaintiff
shall simultaneously provide class expert report(s) with
the motion and make expert(s) available for deposition
thereafter.

December 5, 2014

Last day for Plaintiff to produce and for Defendants to
depose class certification experts, if any, identified in
Plaintiff's Class Certification Motion.

January 5, 2015

Last day for filing Opposition to Class Certification
Motion. Defendants shall simultaneously provide class
expert report(s) with opposition and make expert(s)
available for deposition thereafter.

January 19, 2015

February 20, 2015

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Last day for Defendants to produce and for Plaintiff to
depose class certification experts, if any, identified in
Defendants' Class Certification Opposition.

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Last day for filing Reply to Class Certification
Opposition

April 3, 2015

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Class Certification Hearing

May 11, 2015 at 1:30 p.m.

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IT IS SO ORDERED.
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Dated:

August 5, 2014

/s/ Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO FURTHER EXTEND
DISCOVERY AND BRIEFING SCHEDULES