Hensley-Maclean et al v. Safeway, Inc.

Filing 51

STIPULATION AND ORDER RE 50 BRIEFING SCHEDULE FOR CLASS CERTIFICATION. Motion Hearing set for 7/26/2012 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 7/21/11. (cl, COURT STAFF) (Filed on 7/21/2011)

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*E-Filed 7/21/11* 1 2 3 4 5 6 7 8 9 STEPHEN GARDNER (PRO HAC VICE) CENTER FOR SCIENCE IN THE PUBLIC INTEREST 5646 Milton Street, Suite 211 Dallas, Texas 75206 Counsel for Plaintiffs and the Proposed Class JESSE F. RUIZ, SBN 77984 ROBINSON & WOOD, INC. 227 N. 1st Street San Jose, CA 95113 jfr@robinsonwood.com Tel: (408) 298-7120 Fax: (408) 298-0477 Counsel for Defendant, Safeway, Inc. UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION 12 13 14 15 16 17 DEE HENSLEY-MACLEAN and JENNIFER ROSEN, on behalf of themselves and those similarly situated, Plaintiffs, v. SAFEWAY, INC. and DOES 1-20, Defendants. 18 19 20 21 22 23 24 25 ) ) ) ) ) ) ) ) ) ) ) Case No. CV 11-01230 RS JOINT PROPOSED BRIEFING SCHEDULE FOR CLASS CERTIFICATION (REVISED) Pursuant to the Court's Civil Minute Order dated July 14, 2011 (Doc. 48), the parties submit this Joint Proposed Briefing Schedule for Class Certification. 1. Class Certification. Plaintiffs’ class certification motion pursuant to Federal Rule of Civil Procedure 23 shall be filed with an opening brief on or before April 9, 2012. Defendant’s opposition brief shall be filed no later than 45 days after filing of the motion. Plaintiffs’ reply brief shall be filed no later than 45 days after filing of the opposi- 26 tion brief. After the Court rules on class certification, the parties will submit proposed 27 dates for merits discovery, dispositive motions, and trial. 28 JOINT PROPOSED BRIEFING SCHEDULE FOR CLASS CERTIFICATION Case No. CV 11-01230 RS 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 2. Hearing on Class Certification. Hearing on the class certification motion will be set for July 26, 2012 at 1:30 p.m. 3. Pre-Discovery Disclosures. The parties will exchange the infor- mation required by Fed. R. Civ. P. 26(a)(1) by August 15, 2011. 4. Discovery. The parties will serve all discovery requests so as to be completed by March 15, 2012. As required by Fed.R.Civ.P. 26(a)(2), reports from experts retained relating to class certification are due from the parties by January 16, 2012, and reports from rebuttal experts retained relating to class certification are due by February 15, 2012. 5. Amendment of the Pleadings. All motions to amend the pleadings shall be filed on or before March 26, 2012. 6. Joinder of Parties. All motions to join additional parties shall be filed on or before March 26, 2012. 15 16 Dated: July 21, 2011 17 Respectfully submitted, 18 Center for Science in the Public Interest Robinson & Wood, Inc. Stephen Gardner Seema Rattan 5646 Milton Street, Suite 211 Dallas, TX 75206 Telephone: (214) 827-2774 Facsimile: (214) 827-2787 Lead Counsel for Plaintiffs Jesse F. Ruiz 227 N. 1st Street San Jose, CA 95113 Telephone: (408) 298-7120 Facsimile: (408) 298-0477 Counsel for Defendant, Safeway, Inc. 19 20 21 22 23 24 25 26 27 28 - and Consumer Law Practice of Daniel T. LeBel Dated: 7/21/11 Daniel T. LeBel 601 Van Ness Avenue, Opera Plaza, Suite 2080 San Francisco, CA 94102 IT IS SO ORDERED: RICHARD SEEBORG UNITED STATES DISTRICT JUDGE JOINT PROPOSED BRIEFING SCHEDULE FOR CLASS CERTIFICATION Case No. CV 11-01230 RS 2 1 2 3 4 5 6 7 8 9 10 11 12 13 Telephone: (415) 513-1414 Fascimile: (877) 563-7848 - and Mehri & Skalet, PLLC Steven A. Skalet Craig L. Briskin 1250 Connecticut Ave., N.W., Suite 300 Washington, DC 20036 Telephone: (202) 822-5100 Facsimile: (202) 822-4997 - and The Sturdevant Law Firm, APC James C. Sturdevant Whitney B. Stark 354 Pine Street, Fourth Floor San Francisco CA 94104 Telephone: (415) 477-2410 Facsimile: (415) 477-2420 Counsel for Plaintiffs and the Proposed Class 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT PROPOSED BRIEFING SCHEDULE FOR CLASS CERTIFICATION Case No. CV 11-01230 RS 3

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