Castillo v. ADT, LLC

Filing 27

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 9/24/15 ORDERING that the scheduling order is modified as follows: Expert Disclosures due on 3/7/2016, Rebuttal Expert Disclosures due on 3/21/16, All Discovery to be completed by 4/4/ 16, Motion for Class Cert. to be filed by 5/2/16,Other Motions to be filed by 6/13/16, Pretrial Conference SET for 8/29/16 at 2:00 p.m. and Jury Trial SET for 10/18/16 at 9:00 a.m.. in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Kastilahn, A)

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Linda Claxton (SBN 125729)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
400 South Hope Street, Suite 1200
Los Angeles, CA 90071
Telephone:
213.239.9800
Facsimile:
213.239.9045
Christopher M. Ahearn (SBN 239089)
[e-mail]
Rachel J. Moroski (SBN 286805)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870
Attorneys for Defendant ADT LLC
Alan Harris (SBN 146079)
[e-mail]
Priya Mohan (SBN 228984)
[e-mail]
HARRIS & RUBLE
655 North Central Avenue, 17th Floor
Glendale, California 91203
Telephone:
323.962.3777
Facsimile:
323.962.3004

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David S. Harris (SBN 215224)
NORTH BAY LAW GROUP
116 E. Blithedale Avenue, Suite #2
Mill Valley, California 92941-2024
Telephone:
415.388.8788
Facsimile:
415.388.8770

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Attorneys for Plaintiff RICARDO CASTILLO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RICARDO CASTILLO, individually and on
behalf of all others similarly situated,

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JOINT STIPULATION REGARDING CASE
SCHEDULE; [PROPOSED] ORDER

Plaintiff,

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Case No. 2:15-cv-00383-WBS-DAD

v.
ADT LLC and DOES 1–100, inclusive,
Defendants.

Complaint Filed: February 17, 2015
Trial Date:
October 18, 2016

Case No. 2:15-cv-00383-WBS-DAD
JOINT STIPULATION REGARDING CASE SCHEDULE

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Defendant ADT LLC (hereinafter, “Defendant”) and Plaintiff Ricardo Castillo (hereinafter,

2 “Plaintiff”) (collectively, the “Parties”) respectfully submit this Joint Stipulation Regarding Case
3 Schedule pursuant to page 2, lines 13-24 of the Court’s July 28, 2015 Order denying Defendant’s
4 Motion to Dismiss or Stay, and the discussion at the hearing on said motion.
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WHEREAS, in its June 3, 2015 Status (Pretrial Scheduling) Order (Document 019), the

6 Court set the following schedule:
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Expert Disclosures Due:

October 15, 2015

Rebuttal Expert Disclosures Due:

November 23, 2015

All Discovery Completed:

March 1, 2016

Motion for Class Cert. (filed):

May 2, 2016

Other Motions (filed):

June 13, 2016

Pretrial Conference:

August 29, 2016 at 2:00 p.m.

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Jury Trial:

October 18, 2016 at 9:00 a.m.

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WHEREAS, in its July 28, 2015 Order on Defendant’s Motion to Dismiss/Stay (Document

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16 025), the Court stated that the parties may submit a stipulation for the court’s approval to modify
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the scheduling order.

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WHEREAS, the parties wish to modify the scheduling order as follows:

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Expert Disclosures Due:

March 7, 2016

Rebuttal Expert Disclosures Due:

March 21, 2016

All Discovery Completed:

April 4, 20161

Motion for Class Cert. (filed):

May 2, 2016

Other Motions (filed):

June 13, 2016

Pretrial Conference:

August 29, 2016 at 2:00 p.m.

Jury Trial:

October 18, 2016 at 9:00 a.m.

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The parties stipulate that they will cooperate to ensure that expert depositions may take place as
appropriate during the time period from March 7, 2016 to April 4, 2016.
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Case No. 2:15-cv-00383-WBS-DAD
JOINT STIPULATION REGARDING CASE SCHEDULE; [PROPOSED] ORDER

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties.

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DATED: September 23, 2015

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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
By:

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/s/ Christopher M. Ahearn
Linda Claxton
Christopher M. Ahearn
Rachel J. Moroski

Attorneys for Defendant
ADT LLC

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DATED: September 23, 2015

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By: /s/ Alan Harris (as authorized on 9/23/15)
Alan Harris
Priya Mohan

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HARRIS & RUBLE

DATED: September 23, 2015

NORTH BAY LAW GROUP

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By: /s/ David S. Harris (as authorized on 9/23/15)
David S. Harris

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Attorneys for Plaintiff
RICARDO CASTILLO

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ORDER

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Good cause appearing, IT IS SO ORDERED.

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Dated: September 24, 2015

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Case No. 2:15-cv-00383-WBS-DAD
JOINT STIPULATION REGARDING CASE SCHEDULE; [PROPOSED] ORDER