Kairy et al v. Supershuttle International et al

Filing 132

ORDER GRANTING 131 Stipulation re Anticipated Motions. Signed by Judge Jeffrey S. White on July 2, 2009. (jswlc3, COURT STAFF) (Filed on 7/2/2009)

Case3:08-cv-02993-JSW Document131

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Paul Marron, Esq., State Bar No. 128245 Steven C. Rice, Esq., State Bar No. 109659 Andre Y. Bates, Esq., State Bar No. 178170
MARRON & ASSOCIATES

320 Golden Shore, Suite 410
Long Beach, CA 90802 Tel.: [phone] Fax: [phone]

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E-mail: [e-mail] E-mail: [e-mail]
Robert Jon Hendricks, Esq., State Bar No. 179751
Albert Huang, Esq., State Bar No. 193005

Morgan, Lewis & Bockius LLP 300 South Grand Avenue, Twenty-Second Floor
Los Angeles, CA 90071-3132

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Tel.: [phone] Fax: [phone]
E-mail: [e-mail]
E-mail: [e-mail] Attorneys for Defendants SUPERSHUTTLE
INTERNATIONAL, INC.; SUPERSHUTTLE

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FRANCHISE CORPORATION, Additional Counsel Listed on Next Page

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DISTRICT

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ROOSEVELT KAIRY, LARRY BROWN,
WAYNE DICKSON, DRAKE OSMUN, AND

Case No.: 08-CV-02993-JSW(BZ)
JOINT PROPOSAL RE ANTICIPATED MOTIONS

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HARJINDER SINGHDIETZ On Behalf of Themselves, All Other Similarly Situated,

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And The General Public, Plaintiffs,
vs.

AND ORDER THEREON

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SUPERSHUTTLE INTERNATIONAL, INC.;
SUPERSHUTTLE FRANCHISE

CORPORATION, and DOES I through 20, inclusive,
Defendants.

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Case No. 08-CV-02993-JSW(BZ) JOINT PROPOSAL RE ANTICIPATED MOTIONS - July 2, 2009

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Additional Counsel for Defendants
Rebecca Eisen, Esq., State Bar No. 96129 Ann Marie Reding, Esq., State Bar No. 226864 MORGAN LEWIS & BOCKIUS LLP One Market, Spear Tower San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]

[e-mail] [e-mail]
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Case No. 08-CV-02993-JSVV(BZ) JOINT PROPOSAL RE ANTICIPATED MOTIONS - July 2, 2009

Case3:08-cv-02993-JSW Document131

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Pursuant to the Court's instructions at the June 26, 2009 Case Management Conference,

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the panics submit the following proposed schedule for briefing and hearing upcoming motions and
suggested page limitations for each motion. The parties also propose that a further Case

Management Conference be scheduled along with each motion hearing date set forth below, to

allow the Court and parties to revisit and modify as necessary the motion schedule and related
issues in response to case developments.
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Defendants' Motion to Dismiss for Lack of Subject Matter Jurisdiction (FRCP Rule 12)
and Defendants' Motion to Dismiss for Failure to Join Required Parties (FRCP Rule 19)
A. Motions to be filed: August 17,2009

Briefs on each motion not to exceed 25 pages

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B.

Oppositions to be filed:

September 4,2009

Briefs on each motion not to exceed 25 pages
C. Replies to be filed: September 11,2009

Briefs on each motion not to exceed 15 pages

D.

Hearing date:

September 25,2009

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2.

Plaintiffs' Motion for Certification of Class (FRCP Rule 23)
A.
B.

Motion to be filed:
Brief not to exceed 40 pages

October 16,2009
November 25,2009

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Opposition to be filed:
Brief not to exceed 40 pages

C.
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Reply to be filed:
Brief not to exceed 20 pages

December 23,2009

D.

Hearing date:

January 8,2010

January 15, 2010

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3.

Cross-Motions for Summary Judgment and/or Partial Summary Judgment
A.
B.

Defendants' Motion to be filed:
Plaintiffs' Motion to be filed and

May 7,2010

Plaintiffs' Opposition to be filed:

June 4,2010

C.

Defendants' Opposition to be filed

and Defendants' Reply to be filed:
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July 2, 2010

Case No. 08-CV-02993-JSW(BZ) JOINT PROPOSAL RE ANTICIPATED MOTIONS - July 2, 2009

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D. E.

Plaintiffs' Reply to be filed: Hearing date:

July 16,2010 August 6,2QI0

The parties anticipate requesting an expansion on page limits for these cross-motions. However, as the scope of the motions will depend upon this Court's earlier rulings, the parties are
not yet in a position to give an infonncd estimate of the number of pages necessary to adequately address the issues.

4.

Other Motions

The parties expect that other motions will be filed, including a motion for decertification of
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the FLSA collective action; however, the details of such motions are not sufficiently known to
include them in a schedule at this time.

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Dated: July 2,2009

H1NTON, ALFERT & SUMNER

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By:J:
DAVID POGREL Attorneys for Plaintiffs

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UNIT ED

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ISTRIC ES D TC AT T

MARRON & ASSOCIATES

R NIA

ERED O ORD D IT IS S DIFIE AS MO
Judge Je W ffrey S. hite

RT U O
Attorneys for Defendants

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F D IS T IC T O R

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Case No. 08-CV-02993-JSW(BZ) JOINT PROPOSAL RE ANTICIPATED MOTIONS - July 2, 2009

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