Ellis v. Costco Wholesale Corporation

Filing 799

STIPULATION AND ORDER re 798 STIPULATION WITH PROPOSED ORDER re One-Week Extensions of Dates for (1) 1/29/15 Status Conference, (2) 2/20/15 Non-Expert Discovery Deadline, and (3) Expert-Related Days of 2/20/15, 3/13/15, and 4/3/15 fil ed by Costco Wholesale Corporation Discovery due by 2/27/2015. Status Report due by 1/29/2015. Status Conference set for 2/5/2015 10:30 AM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen.. Signed by Judge Edward M. Chen on 1/23/15. (bpf, COURT STAFF) (Filed on 1/23/2015)

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THE IMPACT FUND
Jocelyn D. Larkin (SBN 110817)
Robert Schug (SBN 249640)
125 University Avenue, Suite 102
Berkeley, CA 94710
Telephone: [phone]
Facsimile: [phone]
[e-mail]

SEYFARTH SHAW LLP
Kenwood C. Youmans (SBN 68258)
David D. Kadue (SBN 113578)
2029 Century Park East, Suite 3500
Los Angeles, California 90067-2901
Telephone: [phone]
Facsimile: [phone]
[e-mail]

LEWIS, FEINBERG, LEE,
RENAKER & JACKSON, P.C.
Bill Lann Lee (SBN 108452)
Lindsay Nako (SBN 239090)
476 9th Street
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]
[e-mail]

SEYFARTH SHAW LLP
Gerald L. Maatman (admitted pro hac vice)
Annette Tyman (admitted pro hac vice)
131 South Dearborn Street
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorneys for Plaintiff Elaine Sasaki

Attorneys for Defendant Costco Wholesale
Corporation

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[Additional Counsel Listed on
Signature Page]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SHIRLEY "RAE" ELLIS, et al.,

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Plaintiffs,
v.
COSTCO WHOLESALE CORPORATION
Defendant.

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Case No. C04 3341 EMC
STIPULATION AND [PROPOSED]
ORDER REGARDING ONE-WEEK
EXTENSIONS OF DATES FOR
(1) 1/29/15 STATUS CONFERENCE,
(2) 2/20/15 NON-EXPERT DISCOVERY
DEADLINE, AND
(3) EXPERT-RELATED DAYS OF
2/20/15, 3/13/15, AND 4/3/15

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STIP AND [PROPOSED] ORDER RE: STATUS CONF. DATE & CERTAIN DISCOVERY DEADLINES
Case No. C04 3341 EMC

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STIPULATION

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The Court’s order of September 5, 2014 (Docket No. 795) set certain trial and pre-trial

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dates, including a trial date of July 27, 2015, a pretrial conference date of June 30, 2015, and

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certain other dates, including, as relevant here:

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A status conference date of January 29, 2015.

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A non-expert discovery deadline of February 20, 2015.

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An expert report deadline of February 20, 2015.

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A rebuttal expert report deadline March 13, 2015.

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An expert discovery deadline of April 3, 2015.

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Lead defense counsel, to avoid a conflict in another matter, desires a one-week extension

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of the status conference to February 5, 2015, and has been advised that space is available on the

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Court’s calendar for that date. Plaintiff’s counsel does not object to the one-week extension of

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the status conference but, because of potential discovery disputes, is agreeable to a one-week

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extension of the status conference only if there are corresponding one-week extensions of related

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discovery dates, set forth above.

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The order stipulated to herein would have no effect on the trial date or the date of the pretrial conference.
Therefore, counsel for Plaintiff, Elaine Sasaki, and counsel for Defendant, Costco
Wholesale Corporation, stipulate as follows:

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1. The status conference now set for 10:30 a.m. on January 29, 2015, shall be re-set to
February 5, 2015.
2. The non-expert discovery deadline now set for February 20, 2015, shall be re-set to
February 27, 2015.

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3. The expert report deadline now set for February 20, 2015, shall be re-set to February
27, 2015.

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STIP AND [PROPOSED] ORDER RE: STATUS CONF. DATE & CERTAIN DISCOVERY DEADLINES
Case No. C04 3341 EMC

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4. The rebuttal expert report deadline now set for March 13, 2015, shall be re-set to
March 18, 2015.

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5. The expert discovery deadline now set for April 3, 2015, shall be re-set to April 10,

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27, 2015.

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IT IS SO STIPULATED.
Dated: January 12, 2015

/s/ Jocelyn D. Larkin
Counsel for Plaintiffs

Dated: January 12, 2015

/s/ David D. Kadue
Counsel for Defendant

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Additional Counsel for Plaintiff:

Additional Counsel for Defendant

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LIEFF, CABRASER, HEIMANN
& BERNSTEIN, LLP
Kelly Dermody (SBN 171716)
Daniel Hutchinson (SBN 239458)
Embarcadero Center West
275 Battery Street, 30th Floor
San Francisco, CA 94111-3339
Telephone: [phone]
Facsimile: [phone]
[e-mail]

SEYFARTH SHAW LLP
David B. Ross (admitted pro hac vice)
620 8th Avenue
32nd Floor
New York, New York 10018
[phone]
[e-mail]

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SEYFARTH SHAW LLP
Thomas J. Wybenga (admitted pro hac vice)
c/o Costco Wholesale Corporation
999 Lake Drive
Issaquah, WA 98027-5367
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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DAVIS, COWELL & BOWE, LLP
Steve Stemerman (SBN 067690)
Elizabeth A. Lawrence (SBN 111781)
595 Market Street, #1400
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]
ALTSHULER BERZON LLP
James M. Finberg (SBN 114850)
177 Post Street, Suite 300
San Francisco, CA 94108
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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STIP AND [PROPOSED] ORDER RE: STATUS CONF. DATE & CERTAIN DISCOVERY DEADLINES
Case No. C04 3341 EMC

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The Court orders as follows:

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED:
1. The status conference now set for 10:30 a.m. on January 29, 2015, shall be re-set to
10:30 a.m. on February 5, 2015.

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2. The non-expert discovery deadline now set for February 20, 2015, shall be re-set to

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February 27, 2015.

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3. The expert report deadline now set for February 20, 2015, shall be re-set to February
27, 2015.

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4. The rebuttal expert report deadline now set for March 13, 2015, shall be re-set to

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March 18, 2015.

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5. The expert discovery deadline now set for April 3, 2015, shall be re-set to April 10,
27, 2015.

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UNIT
ED

Dated: January 23 2015
,

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Honorable Edward M. Chen
RED
UNITED O ORDEDISTRICT COURT
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STIP AND [PROPOSED] ORDER RE: STATUS CONF. DATE & CERTAIN DISCOVERY DEADLINES
Case No. C04 3341 EMC