Gabrielli v. Chipotle Mexican Grill, Inc. et al

Filing 21

STIPULATION AND ORDER TO EXTEND CERTAIN CASE DEADLINES SET BY CASE MANAGEMENT ORDER. Signed by Judge Maxine M. Chesney on January 28, 2010. (mmclc2, COURT STAFF) (Filed on 1/28/2010)

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Eric A. Grover, Esq. (SBN 136080) Jade Butman, Esq. (SBN 235920) KELLER GROVER LLP 425 Second Street, Suite 500 San Francisco, California 94107 Tel. [phone]; Fax: [phone] [e-mail] [e-mail] Scot Bernstein, Esq. (SBN 94915) LAW OFFICES OF SCOT D. BERNSTEIN, A PROFESSIONAL CORPORATION 101 Parkshore Drive, Suite 100 Folsom, California 95630 Tel. [phone] Fax [phone] Attorneys for Plaintiff Marcello Gabrielli UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA MARCELLO GABRIELLI, on behalf of himself, the general public, and as an "aggrieved employee" under the California Labor Code Private Attorneys General Act, Plaintiff, v. CHIPOTLE MEXICAN GRILL, INC., CHIPOTLE MEXICAN GRILL SERVICE CO., LLC., and DOES 1 through 10 inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 09-1511 MMC CLASS ACTION STIPULATION AND [PROPOSED] ORDER TO EXTEND CERTAIN CASE DEADLINES SET BY CASE MANAGEMENT ORDER [Complaint filed March 4, 2009] Trial Date: None Set

STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN CASE DEADLINES

CASE NO.: 09-1511 MMC

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The parties, through their respective counsel, hereby stipulate as follows, and mutually request the Court to approve this Stipulation and enter its Order accordingly: STIPULATION WHEREAS Plaintiff filed the Complaint herein on March 4, 2009 and and Defendants appeared and answered when they removed the case to this Court; WHEREAS an initial case management conference was held on July 24,

WHEREAS at the initial case management conference the Court set a deadline of February 15, 2010 for the cut off of class certification discovery and a deadline of March 29, 2010 for the filing of a motion for class certification; WHEREAS the parties have exchanged initial disclosures and engaged in formal discovery such as requesting and producing documents, propounding interrogatories, and appearing for Plaintiff's deposition; WHEREAS although Defendants have worked diligently to provide discovery responses, meet and confer over the discovery response, and provide supplemental responses, such efforts have taken longer than anticipated by the parties; WHEREAS the parties have been working cooperatively to keep the process of discovery moving along; WHEREAS despite the parties best efforts to comply with the deadlines set by the initial case management order, the parties need additional time to adequately complete class certification discovery and need to extend the deadline for Plaintiff to file his motion for class certification; WHEREAS the parties have mutually agreed to extend the deadline for completing class certification discovery and the deadline for filing Plaintiff's motion for class certification; THEREFORE, the parties stipulate that the deadline for completing class certification discovery currently scheduled for February 15, 2010 should be continued
2 STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN CASE DEADLINES CASE NO.: 09-1511 MMC

1 until May 16, 2010; and the deadline to file Plaintiff's motion for class certification 2 currently set for March 29, 2010 should be continued until June 27, 2010. 3 4 5 6 7 8 9 Dated: January 27, 2010 10 11 12 13 14 15 16 17 Good cause appearing, IT IS HEREBY ORDERED THAT the deadline ORDER By: /s/ GEOFFREY DEBOSKY Attorneys for Defendants Chipotle Mexican Grill, Inc., and Chipotle Mexican Grill Service Co. SHEPPARD MULLIN RICHTER & HAMPTON LLP Dated: January 27, 2010 By: KELLER GROVER LLP /s/ ERIC A. GROVER Attorneys for Plaintiff Marcello Gabrielli

18 for completing class certification discovery currently scheduled for February 15, 2010 is 19 continued until May 16, 2010 and the deadline to file Plaintiff's motion for class 20 certification currently set for March 29, 2010 is continued until June 27, 2010. 21 22 23 24 25 26 27 28
STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN CASE DEADLINES 3 CASE NO.: 09-1511 MMC

January 28, 2010 Date: _________________________

_________________________________ MAXINE M. CHESNEY United States District Court Judge