Harris v. Vector Marketing Corporation

Filing 185

STIPULATION AND ORDER STAYING OBLIGATION UNDER SUBPOENA PENDING DISPOSITION OF PLAINTIFF'S MOTION TO QUASH re #183 Stipulation filed by Alicia Harris. Signed by Judge Edward M. Chen on 6/1/10. (bpf, COURT STAFF) (Filed on 6/1/2010)

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Stanley D. Saltzman, Esq. (SBN 90058) Louis M. Marlin, Esq. (SBN 54053) Marcus J. Bradley, Esq. (SBN 174156) Christina A. Humphrey, Esq. (SBN 226326) MARLIN & SALTZMAN LLP 29229 Canwood Street, Suite 208 Agoura Hills, California 91301 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] [e-mail] (Additional Plaintiff's Counsel on next page) Attorneys for Plaintiff Alicia Harris John P. Zaimes, Esq. (SBN 91933) John H. Lien, Esq. (SBN 222842) REED SMITH LLP 355 South Grand Avenue, Suite 2900 Los Angeles, California 90071-1514 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Defendants VECTOR MARIETING CORPORATION UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ALICIA HARRIS, as an individual and on behalf of all others similarly situated, Plaintiffs, vs. VECTOR MARKETING CORPORATION, a Pennsylvania corporation; and DOES 1 through 20, inclusive, Defendants. Case No.: CV 08 5198 EMC JOINT STIPULATION AND [PROPOSED] ORDER STAYING OBLIGATION UNDER SUBPOENA PENDING DISPOSITION OF PLAINTIFF'S MOTION TO QUASH Assigned to the Hon. Edward M. Chen, Courtroom C

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ADDITIONAL PLAINTIFF'S COUNSEL Daniel H. Chang, Esq. (SBN 183803) Craig S. Hubble, Esq. (SBN 200789) Larry W. Lee, Esq. (SBN 228175) DIVERSITY LAW GROUP 444 S. Flower Street Citigroup Center, Suite 1370 Los Angeles, California 90071 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] Sherry Jung, Esq. (SBN 234406) LAW OFFICES OF SHERRY JUNG 448 S. Hill St., Ste. 605 Los Angeles, California 90013 Telephone: [phone] Facsimile: [phone] [e-mail]

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Plaintiff Alicia Harris ("Plaintiff") and defendant, Vector Marketing Corp. ("Defendant"), by and through their counsel of record, hereby stipulate and agree as follows: WHEREAS, Defendant served subpoenas upon Pasadena High School, CIS Academy, Pasadena City College, and John Muir High School seeking production of records relating to Plaintiff's academic performance and evaluations, transcript of grades and course enrollment, dates of enrollment, attendance, any academic diagnostic examinations and examination scores, and any education, academic proficiency, or other related testing administed to Plaintiff. WHEREAS, Plaintiff intends to promptly file a Motion to Quash said subpoenas. WHEREAS, the filing of a Motion to Quash does not stay obligations of recipients to comply with their obligations under a subpoena. WHEREAS, the Court's disposition of Plaintiff's Motion to Quash could affect the parties' obligations under the subpoena. WHEREAS, Plaintiff's counsel and Defendant's counsel believes it is in their mutual best interests to stay Pasadena High School, CIS academy, Pasadena City College, and John Muir High School's obligations pursuant to the subpoena, for a period of time not to exceed forty-five days from the date of the entry of the proposed order herein. NOW THEREFORE, IT IS HEREBY STIPULATED by the parties herein, through their counsel of record, as follows: (1) The date for production of the documents requested in the subpoenas to Pasadena High School, CIS academy, Pasadena City College, and John Muir High School shall be stayed pending the Court's disposition of Plaintiff's Motion to Quash, for a period of time not to exceed forty-five days from the date of the entry of the proposed order herein. The Parties will notify the recipients of the subpoenas immediately following the Court's issuance of its Order on the Motion to Quash, as to whether compliance is still required, and if so, on what date compliance is to be completed; /// ///

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(2) Plaintiff will file her motion to quash on or before June 4, 2010. IT SO STIPULATED.

Dated: May 27, 2010

MARLIN & SALTZMAN

By: ___________/S/ ____________ Christina A. Humphrey, Esq. Attorneys for Plaintiff Dated: May 27, 2010 REED SMITH, LLP By: ___________/S/_______________ Roxanne M. Wilson, Esq. Attorneys for Defendant I, Christina A. Humphrey, attest that I have obtained concurrence from Roxanne M. Wilson in the filing of this Stipulation. See N.D. Cal. General Order 45 § 10(B).

[PROPOSED] ORDER

GOOD CAUSE APPEARING, IT IS SO ORDERED,

UNIT ED

June 1, 2010 DATED: _____________________

________________________________ HONORABLE EDWARD M. CHEN

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