Harris v. Vector Marketing Corporation

Filing 206

STIPULATION AND ORDER RE STAY OF PRODUCTION OF PLAINTIFF'S EMPLOYMENT RECORDS re 205 Stipulation, filed by Alicia Harris. Signed by Judge Edward M. Chen on 7/19/10. (bpf, COURT STAFF) (Filed on 7/19/2010)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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: (818) 991-8080 Facsimile: (818) 991-8081 ssaltzman@marlinsaltzman.com louis.marlin@marlinsaltzman.com mbradley@marlinsaltzman.com chumphrey@marlinsaltzman.com (Additional Plaintiff's Counsel on next page) Attorneys for Plaintiff Alicia Harris John P. Zaimes, Esq. (SBN 91933) John H. Lien, Esq. (SBN 222842) Roxanne M. Wilson, Esq. (SBN 94627) REED SMITH LLP 355 South Grand Avenue, Suite 2900 Los Angeles, California 90071-1514 Telephone: +1 213 457 8000 Facsimile: +1 213 457 8080 jzaimes@reedsmith.com jlien@reedsmith.com rwilson@reedsmith.com 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, Case No.: CV 08 5198 EMC JOINT STIPULATION RE: STAY OF Plaintiffs, PRODUCTION OF PLAINTIFF'S vs. EMPLOYMENT RECORDS PENDING DISPOSITION OF PLAINTIFF'S VECTOR MARKETING CORPORATION, a MOTIONS TO QUASH SUBPOENAS AND Pennsylvania corporation; and DOES 1 through SHORTENING TIME ON SAID 20, inclusive, MOTIONS; [PROPOSED] ORDER Defendants. Assigned to the Hon. Edward M. Chen, Courtroom C 1 JOINT STIPULATION AND [PROPOSED] ORDER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 JOINT STIPULATION AND [PROPOSED] ORDER 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: (213) 488-0655 Facsimile: (213) 488-6554 dchang@diversitylaw.com chubble@diversitylaw.com lwlee@diversitylaw.com Sherry Jung, Esq. (SBN 234406) LAW OFFICES OF SHERRY JUNG 444 S. Flower Street Citigroup Center, Suite 1370 Los Angeles, California 90071 Telephone: (213) 488-0655 Facsimile: (213) 488-6554 Sherryj23@hotmail.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff Alicia Harris ("Plaintiff") and Defendant Vector Marketing Corp. ("Defendant") (collectively, the "Parties"), by and through their counsel of record, hereby stipulate and agree as follows: WHEREAS, Defendant served subpoenas upon Radio Shack Corporation, Macy's Inc., and Pinkberry Inc. seeking production of Plaintiff's employment records ("Employment Records Subpoenas"). WHEREAS, Plaintiff intends to promptly file Motions to Quash said Employment Records Subpoenas. WHEREAS, the filing of the Motions to Quash does not preclude compliance with Defendant's validly issued Employment Records Subpoenas. WHEREAS, the Court's disposition of Plaintiff's Motions to Quash could affect the scope production and the third parties' obligations to comply with the Employment Records Subpoena. WHEREAS, the certification briefings are set to be filed in September 2010, and the production of Plaintiff's employment records may be relevant to the claims and defenses addressed in the Parties' certification papers. NOW THEREFORE, IT IS HEREBY STIPULATED by the Parties herein, through their counsel of record, as follows: (1) Plaintiff shall file her Motions to Quash the Employment Records Subpoenas on or before Friday, July 23, 2010, Defendant shall file its opposition to the Motions to Quash on or before July 30, 2010, and Plaintiff shall file her Reply on or before August 4, 2010. (2) The Motions to Quash shall be heard on August 11, 2010, at 10:30 a.m., or on a date or time as soon thereafter as convenient for the Court. If, for the convenience of the Court, 3 JOINT STIPULATION AND [PROPOSED] ORDER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the Motions to Quash cannot be heard on August 11, 2010 due to the Court's docket, the parties agree to telephonic appearances on any other available hearing date and if the Court finds oral arguments helpful and necessary to the disposition of said Motions. (3) The date for production of the documents requested in the subpoenas to Radio Shack Corporation, Macy's Inc., and Pinkberry Inc. shall be stayed pending the Court's order on Plaintiff's Motions to Quash, provided that Plaintiff files her Motions to Quash on or before July 23, 2010. (4) The Parties shall jointly notify the recipients of the Employment Records Subpoenas immediately following the Court's issuance of its Order on the Motions to Quash. To the extent Plaintiff fails to file her Motions to Quash on or before July 23, 2010, Vector shall inform the recipients of the Employment Records Subpoenas of their duty to timely comply with the validly issued subpoenas given Plaintiff's non-compliance with this Joint Stipulation and Order. Dated: July 16, 2010 MARLIN & SALTZMAN By: ___________/S/ ____________ Christina A. Humphrey, Esq. Attorneys for Plaintiff Dated: July 16, 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). 4 JOINT STIPULATION AND [PROPOSED] ORDER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2010; 2010; GOOD CAUSE APPEARING, IT IS SO ORDERED, that: (1) Plaintiff shall file her Motions to Quash the Employment Subpoenas on or before Friday, July 23, 2010; (2) Defendant shall file its opposition to the Motions to Quash on or before July 30, (3) Plaintiff shall her reply in support of the Motions to Quash on or before August 4, (4) The hearing on the Motions to Quash shall be set for August 11, 2010 or as soon thereafter as may be convenient for the Court. UNIT ED HONORABLE EDWARD M. CHEN S 7/19/10 DATED: _____________________ ISTRIC ES D TC T TA ________________________________ ER N F D IS T IC T O R 5 JOINT STIPULATION AND [PROPOSED] ORDER A C LI FO dward Judge E M. Che n R NIA OO IT IS S RDERE D RT U O NO RT H

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