Rodman v. Safeway, Inc.
Filing
425
ORDER re 421 Joint Case Management Statement filed by Michael Rodman. Signed by Judge Jon S. Tigar on February 18, 2016. (wsn, COURT STAFF) (Filed on 2/18/2016)
1 James C. Shah (SBN 260435)
SHEPHERD, FINKELMAN, MILLER & SHAH, LLP
2 401 West A Street, Suite 2350
3 San Diego, CA 92101
Telephone: (619) 235-2416
4 Facsimile: (619) 235-7334
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jshah@sfmslaw.com
CHIMICLES & TIKELLIS LLP
6 Steven A. Schwartz
7 Timothy N. Mathews
361 W. Lancaster Avenue
8 Haverford, PA 19041
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Telephone: (610) 642-8500
Attorneys for Plaintiff and on Behalf
of All Others Similarly Situated
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Scott D. Baker (SBN 84923)
12 Jonah D. Mitchell (SBN 203511)
James A. Daire (SBN 239637)
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Christine M. Morgan (SBN 169350)
14 REED SMITH LLP
101 Second Street, Suite 1800
15 San Francisco, CA 94105
16 Telephone: (415) 543-8700
17 Attorneys for Defendant
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SAFEWAY INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
21 MICHAEL RODMAN, on behalf of himself
Case No. 3:11-CV-03003 JST (JCS)
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JOINT CASE MANAGEMENT REPORT
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and all others similarly situated,
Plaintiff,
v.
SAFEWAY INC.,
Defendant.
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Date:
February 24, 2016
Time:
2:00 PM
Courtroom: 9 – 19th Floor
The Honorable Jon S. Tigar
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SMRH:436004263.3
JOINT CASE MANAGEMENT REPORT
Case No. C11-03003 JST (JCS)
Plaintiff, Michael Rodman (“Plaintiff”) and Defendant, Safeway Inc.
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2 (“Safeway”) submit this Status Report to provide an update on three issues currently
3 pending before this Court, which are: the bill of costs; a proposed interim notice to
4 Class Members of entry of the judgment; and a briefing schedule for Plaintiff’s
5 anticipated motion for discovery sanctions. The parties are filing concurrently
6 herewith two stipulations that, subject to Court approval, resolve the issues
7 concerning the bill of costs and the proposed interim notice. The parties have also
8 agreed to a briefing schedule for Plaintiff’s motion for sanctions, which is set forth
9 below. As such, the parties believe the Case Management Conference currently
10 scheduled for February 24, 2016 can be taken off calendar. Alternatively, Plaintiff
11 will file herewith a request to appear telephonically.
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A.
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The parties have reached agreement on a stipulated amount of $95,000.00 for
Bill of Costs
15 Plaintiff’s Bill of Costs incurred through the date of the approximately $41.9 million
16 judgment. The parties are submitting a stipulation to that effect today.
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B.
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The parties have agreed to send a notice to class members to provide them
Notice of Entry of Judgment to Class Members
20 with an update on the status of the case, and also reminding Class members that they
21 should contact Class counsel in the event that their address or contact information
22 changes prior to resolution of the litigation. The parties have agreed on the content
23 of the notice and manner of distribution, and are submitting a stipulation and
24 proposed order seeking approval today.
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H0052020.
JOINT CASE MANAGEMENT REPORT
Case No. C11-03003 JST (JCS)
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C.
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The parties have engaged in meet and confer discussions regarding Plaintiff’s
Plaintiff’s Motion for Sanctions
3 anticipated motion for discovery sanctions but have been unable to reach any
4 agreement that obviates the need to file the motion. The parties propose the
5 following briefing schedule:
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March 16, 2016 – Deadline for Plaintiff to file motion for
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sanctions
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April 13, 2016 – Deadline for Defendant to respond
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May 4, 2016 – Plaintiff’s Reply
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May 19, 2016 (or such other date as the Court may choose) –
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Hearing on Plaintiff’s motion for sanctions
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A proposed order setting the above schedule is attached hereto.
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17 By:
/s/ Jonah D. Mitchell_________
Scott D. Baker (SBN 84923)
Jonah D. Mitchell (SBN 203511)
James A. Daire (SBN 239637)
Christine M. Morgan (SBN 169350)
101 Second Street, Suite 1800
San Francisco, CA 94105
Telephone: (415) 543-8700
Facsimile: (415) 391-8269
CHIMICLES & TIKELLIS LLP
REED SMITH LLP
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Attorneys for Defendant
SAFEWAY INC.
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By:
/s/ Timothy N. Mathews_________
Steven A. Schwartz (pro hac vice)
Timothy N. Mathews (pro hac vice)
361 W. Lancaster Ave.
Haverford, PA 19041
Telephone:
(610) 642-8500
Facsimile:
(610) 649-3633
James C. Shah (SBN 260435)
Rose F. Luzon (SBN 221544)
SHEPHERD, FINKELMAN,
MILLER & SHAH
401 West A Street, Suite 2350
San Diego, CA 92101
Telephone:
(619) 235-2416
Facsimile:
(866) 300-7367
Attorneys for Plaintiff
MICHAEL RODMAN and the Class
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H0052020.
JOINT CASE MANAGEMENT REPORT
Case No. C11-03003 JST (JCS)
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[PROPOSED] ORDER
The Court sets the following deadline for Plaintiff’s anticipated Motion for
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3 Discovery Sanctions:
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March 16, 2016
Deadline for Plaintiff to file motion for sanctions
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April 13, 2016
Deadline for Defendant to respond
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May 4, 2016
Plaintiff’s Reply
Hearing on Plaintiff’s motion for sanctions
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S
RT
HON. JON S. TIGAR
. Ti ga r
ge J o n S
Jud
ER
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R NIA
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, 2016
UNIT
ED
10 Date: February
VED
APPRO
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U
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9 IT IS SO ORDERED.
S DISTRICT
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H0052020.
JOINT CASE MANAGEMENT REPORT
Case No. C11-03003 JST (JCS)
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