Gosling v. Groupon, Inc.
Filing
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STIPULATION and [Proposed] Order for Continuance of Case Management Conference and Related Dates by Sarah Gosling, Groupon, Inc.. (Weiss, Shirli) (Filed on 4/28/2011)
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SHIRLI F. WEISS (Bar No. 079225)
CHRISTOPHER M. YOUNG (Bar No. 163319)
NOAH A. KATSELL (Bar No. 217090)
DLA PIPER LLP (US)
401 B Street, Suite 1700
San Diego, CA 92101-4297
Tel: 619.699.2700
Fax: 619.699.2701
shirli.weiss@dlapiper.com
christopher.young@dlapiper.com
noah.katsell@dlapiper.com
PAUL J. HALL (Bar No. 66084)
DLA PIPER LLP (US)
555 Mission Street Suite 2400
San Francisco, CA 94105
Tel: 415.836.2500
Fax: 619.699.2701
paul.hall@dlapiper.com
Attorneys for Defendant
GROUPON, INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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SARAH GOSLING, on Behalf of Herself
and All Other Similarly Situated and the
General Public,
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Plaintiff,
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CASE NO. 3:11-cv-01038 (CRB)
STIPULATION AND [PROPOSED]
ORDER FOR CONTINUANCE OF CASE
MANAGEMENT CONFERENCE AND
RELATED DATES
v.
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Case Management Conference:
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GROUPON, INC., and DOES 1 through
100, inclusive,
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Defendants.
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Date:
Time:
Courtroom:
Judge:
June 17, 2011
8:30 a.m.
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Hon. Charles R. Breyer
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DLA P IPER LLP (US)
SAN FRANCISCO
EAST\44626886.2
STIPULATION FOR CONTINUANCE OF CMC AND ATTENDANT DATES
CASE NO. 3:11-CV-01038 (CRB)
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Plaintiff Sarah Gosling (“Plaintiff”) and Defendant Groupon, Inc. (“Groupon”) by and
through their respective attorneys of record, stipulate as follows:
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1.
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8:30 a.m.
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2.
The initial Case Management Conference in this action is set for June 17, 2011 at
Pursuant to the Order Setting Initial Case Management Conference and the Clerk’s
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Notice dated March 14, 2011, the deadline to file the Rule 26(f) Report, complete initial
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disclosures or state objections to initial disclosures in the Rule 26(f) Report, and file the Case
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Management Conference Statement is June 10, 2011, and the deadline for the parties to meet and
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confer pursuant to Rule 26(f), file the ADR Certification, and file either a stipulation to ADR
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Process or Notice of Need for ADR Phone Conference is May 24, 2011.
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3.
On May 16, 2011, the Judicial Panel on Multidistrict Litigation (“JPML”) will
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hear a motion to consolidate this case, along with other cases pending against Groupon
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and certain "retailer" defendants in various district courts and involving similar allegations
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(“MDL Motion”).
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4.
The parties have previously stipulated and agreed to extend Groupon’s time to
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respond to the complaint until (i) 45 days after the filing of a Consolidated Amended Complaint
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or whatever other deadline is set by the transferee court, in the event the JPML grants the MDL
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Motion, or (ii) 45 days after service of the JPML’s decision on the MDL Motion to consolidate or
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whatever deadline is set by this Court, in the event the JPML denies the MDL Motion to
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consolidate.
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5.
In light of the above, the parties hereby stipulate and request that the Court stay all
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currently pending dates and deadlines in this matter, including the Case Management Conference
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currently scheduled for June 17, 2011 at 8:30 a.m., pending the JPML’s decision on the MDL
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Motion. The parties further request that in the event the JPML denies the MDL Motion, the
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DLA P IPER LLP (US)
SAN FRANCISCO
EAST\44626886.2
STIPULATION FOR CONTINUANCE OF CMC AND ATTENDANT DATES
CASE NO. 3:11-CV-01038 (CRB)
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Court reset the Case Management Conference for a date no sooner than 45 days after service of
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the JPML’s decision on the MDL Motion.
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IT IS SO STIPULATED.
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Dated: April 28, 2011
DLA PIPER LLP (US)
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By s/ Christopher M. Young
SHIRLI F. WEISS
PAUL J. HALL
CHRISTOPHER M. YOUNG
NOAH A. KATSELL
Attorneys for Defendant
GROUPON, INC.
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Dated: April 28, 2011
ROBBINS GELLER RUDMAN & DOWD LLP
By s/ John J. Stoia, Jr.
JOHN J. STOIA, JR.
RACHEL L. JENSEN
PHONG L. TRAN
Attorneys for Plaintiff
SARAH GOSLING
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I, Christopher M. Young, attest that concurrence in the filing of this document has been
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obtained from each of the signatories. I declare under penalty of perjury under the laws of the
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United States of America that the foregoing is true and correct. Executed on this 28th day of
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April, 2011 at San Diego, California.
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By: s/ Christopher M. Young
CHRISTOPHER M. YOUNG
Attorney for Defendant Groupon, Inc.
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DLA P IPER LLP (US)
SAN FRANCISCO
EAST\44626886.2
STIPULATION FOR CONTINUANCE OF CMC AND ATTENDANT DATES
CASE NO. 3:11-CV-01038 (CRB)
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ORDER
PURSUANT TO STIPULATION AND GOOD CAUSE APPEARING, IT IS HEREBY
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ORDERED that all dates and deadlines in this matter are stayed pending the decision of the
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Judicial Panel on Multidistrict Litigation (“JPML”) on the MDL Motion to consolidate. The Case
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Management Conference currently scheduled for June 17, 2011 at 8:30 a.m. is taken off calendar,
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and shall be rescheduled for a date no sooner than 45 days after service of the JPML’s decision on
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the MDL Motion, in the event the JPML denies the MDL Motion.
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IT IS SO ORDERED.
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Dated: April ___, 2011
The Hon. Charles R. Breyer
U.S. District Court Judge
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DLA P IPER LLP (US)
SAN FRANCISCO
EAST\44626886.2
STIPULATION FOR CONTINUANCE OF CMC AND ATTENDANT DATES
CASE NO. 3:11-CV-01038 (CRB)
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