Kirchner v. Shred-It USA, Inc. et al

Filing 22

STIPULATION and ORDER 21 signed by Senior Judge William B. Shubb on 9/24/2014 continuing the Scheduling Conference to 1/5/2015 at 02:00 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. A Joint Status Report shall be filed no later than December 22, 2014. (Kirksey Smith, K)

1
2
3
4
5
6
7
8
9
10

SEYFARTH SHAW LLP
Mark P. Grajski (SBN 178050)
[e-mail]
400 Capitol Mall, Suite 2350
Sacramento, California 95814-4428
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
FIRST ADVANTAGE LNS
SCREENING SOLUTIONS, INC.
THE DION-KINDEM LAW FIRM
Peter R. Dion-Kindem, P.C.
Peter R. Dion-Kindem (SBN 95267)
[e-mail]
21550 Oxnard Street, Suite 900
Woodland Hills, California 91367
Telephone: [phone]
Facsimile: [phone]

11
12
13
14

THE BLANCHARD LAW GROUP, APC
Lonnie C. Blanchard, III (SBN 93530)
[e-mail]
3311 East Pico Boulevard
Los Angeles, California 90023
Telephone: [phone]
Facsimile: [phone]

QUINN EMANUEL URQUHART
& SULLIVAN, LLP
Shon Morgan (SBN 187736)
[e-mail]
865 South Figueroa Street, 10th Floor
Los Angeles, California 90017-2543
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff
MICHAEL KIRCHNER

Attorneys for Defendant
SHRED-IT USA INC. n/k/a SHRED-IT USA LLC

15
16
17

UNITED STATES DISTRICT COURT

18

EASTERN DISTRICT OF CALIFORNIA

19
20

MICHAEL KIRCHNER, an individual, on behalf
of himself and all others similarly situated,,

21
22
23
24
25

Plaintiff,
v.
SHRED-IT USA INC., a Delaware Coporation,
FIRST ADVANTAGE LNS SCREENING
SOLUTIONS, INC., and DOES 1 through 10, ,

Case No. 2:14-cv-01437-WBS-EFB
STIPULATION OF ALL PARTIES TO
CONTINUE STATUS (PRETRIAL
SCHEDULING) CONFERENCE AND
STAY DISCOVERY PENDING RULING
ON DEFENDANTS’ RESPECTIVE
MOTIONS TO DISMISS; [PROPOSED]
ORDER

Defendants.

26
27
28
STIPULATION OF ALL PARTIES TO CONTINUE STATUS (PRETRIAL SCHEDULING) CONFERENCE AND
STAY DISCOVERY PENDING RULING ON DEFENDANTS’ RESPECTIVE MOTIONS TO DISMISS

1

Plaintiff MICHAEL KIRCHNER and Defendants FIRST ADVANTAGE LNS SCREENING

2

SOLUTIONS, INC. (“First Advantage”), and SHRED-IT USA INC. (“Shred-It”) (collectively,

3

“Defendants”), by their counsel and pursuant to Eastern District Local Rule 144(a), stipulate and agree

4

as follows:

5

1.

First Advantage and Shred-It, if it so chooses, will file their Motions to Dismiss

6

Plaintiff’s First Amended Class Action Complaint on or before October 6, 2014, noticed for hearing on

7

November 17, 2014.

8

2.

The parties will hold a Rule 26(f) conference on Tuesday, September 23, 2014.

9

3.

The parties may serve discovery following the Rule 26(f) conference; however,

10

responses and/or objections shall not be due until thirty (30) days following the Court’s ruling(s) on the

11

Motion(s) to Dismiss Plaintiff’s First Amended Class Action Complaint.

12

4.

The Status (Pretrial Scheduling) Conference will be continued to the date twenty-

13

one (21) days after the Court’s ruling(s) on the Motion(s) to Dismiss Plaintiff’s First Amended Class

14

Action Complaint. Pursuant to Local Rule 240, the parties will submit to the Court a JOINT Status

15

Report fourteen (14) days prior to the hearing date for the Status (Pretrial Scheduling) Conference.

16
17

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: September 23, 2014

Respectfully submitted,

18

SEYFARTH SHAW LLP

19

By: /s/ Mark P. Grajski
Mark P. Grajski

20

Attorneys for Defendant
FIRST ADVANTAGE LNS SCREENING
SOLUTIONS, INC.

21
22
23

DATED: September 23, 2014

THE DION-KINDEM LAW FIRM

24

By: /s/ Peter R. Dion-Kindem
Peter R. Dion-Kindem

25

Attorneys for Plaintiff
MICHAEL KIRCHNER

26
27
28
1

STIPULATION OF ALL PARTIES TO CONTINUE SCHEDULING CONFERENCE/STAY DISCOVERY PENDING
RULING ON DEFENDANTS’ RESPECTIVE MOTIONS TO DISMISS

1

DATED: September 23, 2014

QUINN EMANUEL URQUHART
& SULLIVAN LLC

2
By: /s/ Shon Morgan
Shon Morgan

3
4

Attorneys for Defendant
SHRED-IT USA INC. n/k/a SHRED-IT USA LLC

5
6

ORDER

7
8
9
10

IT IS SO ORDERED. The Status (Pretrial Scheduling) Conference is continued to January 5,
2015 at 2:00 p.m. A Joint Status Report shall be filed no later than December 22, 2014.
Dated: September 24, 2014

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
STIPULATION OF ALL PARTIES TO CONTINUE SCHEDULING CONFERENCE/STAY DISCOVERY PENDING
RULING ON DEFENDANTS’ RESPECTIVE MOTIONS TO DISMISS
18077623v.3