Wren et al v. RGIS Inventory Specialists

Filing 700

STIPULATION AND ORDER SEEKING ONE-WEEK CONTINUANCE FOR SUBMISSION OF JOINT CASE MANAGEMENT PLAN, PER COURT'S FEBRUARY 6, 2009 ORDER. Signed by Judge Joseph C. Spero on 02/23/09. (klh, COURT STAFF) (Filed on 2/23/2009)

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CHERYL D. ORR (State Bar No. 143196) HEATHER M. SAGER (State Bar No. 186566) S. FEY EPLING (State Bar No. 190025) DRINKER BIDDLE & REATH LLP 50 Fremont Street, 20th Floor San Francisco, California 94105-2235 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] [e-mail] [e-mail] Attorneys for Defendant RGIS, LLC, erroneously sued herein as RGIS INVENTORY SPECIALISTS, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION Trisha Wren, et al., Plaintiffs, v. RGIS Inventory Specialists, Inc., Defendant. Case No. 3:06-cv-5778 (JCS)

STIPULATION AND [PROPOSED[ ORDER SEEKING ONE-WEEK CONTINUANCE FOR SUBMISSION OF JOINT CASE MANAGEMENT PLAN, PER COURT'S FEBRUARY 6, 2009 ORDER Honorable Joseph C. Spero

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DRINKER BIDDLE & REATH LLP 50 Fremont Street, 20th Floor San Francisco, CA 94105

Plaintiffs Trisha Wren, et al. ("Plaintiffs") and Defendant RGIS, LLC (erroneously sued as RGIS Inventory Specialists, Inc.) ("RGIS") (collectively, the "Parties") submit the following Stipulation and [Proposed] Order Regarding Timing of Joint Case Management Submission, pursuant to the Court's February 6, 2009 Order (the "Order"): The Court's Order instructed the Parties to "meet and confer and submit to the Court within the next fourteen (14) days a proposed schedule for the remainder of the case, including dates for submitting to the Court a proposed notice to class members." See Order, Docket No. 694, at 54:19-21. The fourteen day period contemplated by the Order will elapse this Friday, February 20.

STIPULATION AND [PROPOSED] ORDER SEEKING ONE-WEEK CONTINUANCE OF JOINT CASE MANAGEMENT SUBMISSION
601378

CASE NO. 3:06-CV-5778 (JCS)

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DRINKER BIDDLE & REATH LLP 50 Fremont Street, 20th Floor San Francisco, CA 94105

On Monday, February 9 (the first business day following the issuance of the Order), counsel for Plaintiff reached out to counsel for RGIS to schedule the meet and confer session. Counsel for RGIS promptly responded, and the Parties agreed to meet on Tuesday, February 17, the first date all counsel were available to discuss these issues. Early in the day on February 17, counsel for Plaintiff informed counsel for RGIS that they have a family medical issue they need to attend to, and asked whether the Parties could reschedule their discussion. Counsel for RGIS informed Plaintiff's counsel that they would be out of town and/or in deposition the remainder of the week and, thus, today was their only available day to meet and confer. Given the foregoing scheduling challenges, the Parties agreed to request the Court's permission for an additional week in which to meet and confer and prepare their submission. The Parties have stipulated to complete this process and submit the requested statement to the Court by Friday, February 27, and by this submission ask the Court's permission for this one-week continuance. IT IS SO STIPULATED.

February 17, 2009

SCHNEIDER WALLACE COTTRELL BRAYTON KONECKY LLP

By:

/s/Guy B. Wallace/s/ Guy B. Wallace Counsel for Plaintiffs

February 17, 2009

DRINKER, BIDDLE & REATH LLP

By:

/s/Cheryl D. Orr/s/ Cheryl D. Orr Heather M. Sager Counsel for RGIS, LLC

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STIPULATION AND [PROPOSED] ORDER SEEKING ONE-WEEK CONTINUANCE OF CASE MANAGEMENT SUBMISSION

601378.1

CASE NO. 3:06-CV-5778 (JCS)

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DRINKER BIDDLE & REATH LLP 50 Fremont Street, 20th Floor San Francisco, CA 94105

The Court has considered the grounds for the stipulation recorded herein and, finding that all Parties are acting in good faith and that good cause exists for accepting the stipulation, hereby endorses the Parties' request for a one-week continuance in which to submit the joint case management plan ordered by the Court via its February 6, 2009 Order (Docket No. 694). IT IS SO ORDERED. 23 Dated: February ____, 2009

______________________________ HON. JOSEPH C. SPERO
seph C. Judge Jo Spero

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STIPULATION AND [PROPOSED] ORDER SEEKING ONE-WEEK CONTINUANCE OF CASE MANAGEMENT SUBMISSION

601378.1

CASE NO. 3:06-CV-5778 (JCS)

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