Field v. American Mortgage Express Corporation et al

Filing 55

STIPULATION AND ORDER amending briefing schedules for summary judgment motions; Signed by Judge Marilyn Hall Patel on 3/30/2011. (awb, COURT STAFF) (Filed on 3/30/2011)

1 Lorraine P. Ocheltree (SBN 151791) Allegra A. Jones (SBN 236518) 2 DUANE MORRIS LLP One Market, Spear Tower, Suite 2200 3 San Francisco, CA 94105-1127 Telephone: [phone] Facsimile: 415.957.3001 E-Mail: [e-mail] [e-mail] 5 6 Eric P. Berezin (Admitted Pro Hac Vice) 7 DUANE MORRIS LLP Atlantic Center Plaza 8 1180 West Peachtree Street NW, Suite 700 Atlanta, GA 30309-3448 9 Telephone: [phone] Facsimile: 404.253.6901 [e-mail] 10 E-mail: 11 Attorneys for Defendant GEVITY HR, INC. 12 13 14 15

Harry G. Lewis (SBN 157705) Gordon W. Renneisen (SBN 129794) Julie A. Marquis (SBN 178466) CORNERSTONE LAW GROUP 595 Market Street, Suite 2360 San Francisco, CA 94105 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff MARSHALL FIELD and all other similarly situated persons

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA Case No.: C 09-05972 MHP JOINT STIPULATION AND [PROPOSED] ORDER REGARDING MOTION FOR SUMMARY JUDGMENT SCHEDULE

16 MARSHALL FIELD, individually and on behalf of all other similarly situated persons, 17 Plaintiffs, 18 v. 19 AMERICAN MORTGAGE EXPRESS CORP., a 20 Pennsylvania Corporation and GEVITY HR, INC., a Florida Corporation, 21 Defendants. 22 23

Plaintiff Marshall Field (`Field"), by and through his undersigned counsel, and Defendant

24 Gevity HR, Inc. ("Gevity"), by and through its undersigned counsel, hereby enter into the following 25 Joint Stipulation: 26 WHEREAS this Court issued an Order regarding the dates for the filing of the parties'

27 respective motions for summary judgment and/or summary adjudication of issues ("Motions"); 28 WHEREAS, the parties are seeking to informally resolve a discovery dispute prior to filing
JOINT STIPULATION AND PROPOSED ORDER

1 their Motions, and need additional time to meet and confer. 2 3 4 5 6 7 8 9 10 Dated: March 29, 2011 11 12 13 14 15 Dated: March 29, 2011 16 17 18 19 20 21 Dated: March __, 2011 30 22 23 24 25 26 27 28 2
JOINT STIPULATION AND PROPOSED ORDER

NOW, THEREFORE, Field and Gevity hereby stipulate and agree as follows: 1. 2. The deadline for the parties to file their Motions is continued to May 2, 2011; The deadline for the parties to file their opposition to the Motions is continued to May 16, 2011; 3. The deadline for the parties to file their reply to any opposition to the Motions is continued to May 23, 2011; and 4. The hearing on the Motions shall be conducted on June 6, 2011. or such other date as the court may set. DUANE MORRIS LLP By: ______/s/ ____ Eric P. Berezin Lorraine P. Ocheltree Allegra A. Jones Attorneys for Defendant GEVITY HR, INC. CORNERSTONE LAW GROUP By: /s/ _______ Harry G. Lewis Attorneys for Plaintiff MARSHALL FIELD

IT IS SO ORDERED.

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DERE __________ SO OR Patel IT I Marilyn H. Honorable Judge S Judge of the United States District Court
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