Boysen v. Walgreen Co.

Filing 24

ORDER signed on 5/18/12 by Judge Illston STIPULATION WITH PROPOSED ORDER re 14 MOTION to Dismiss Plaintiffs Oppositions to the Motions, currently due on May 21 (14 days after service and filing per Local Rule 7-3), shall be due on June 4, 2012.Defe ndants Replies in Support of the Motions, currently dueMay 28 (7 days after the Oppositions are filed and served), shall be due on June 18, 2012.The currently noticed hearing date on both Motions, of June 15, 2012, shall be extended to July 20, 2012, 18 MOTION to Stay Proceedings Pending MDL Consideration TO MODIFY HEARING DATE AND BRIEFING DEADLINES filed by Randy Boysen., Motions terminated: 22 STIPULATION WITH PROPOSED ORDER re 14 MOTION to Dismiss , 18 MOTION to Stay Proceedings Pending MDL Consideration TO MODIFY HEARING DATE AND BRIEFING DEADLINES filed by Randy Boysen. (tfS, COURT STAFF) (Filed on 5/18/2012)

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Tina Wolfson, SBN 174806
[e-mail]
Robert Ahdoot, SBN 172098
[e-mail]
AHDOOT & WOLFSON, P.C.
10850 Wilshire Boulevard, Suite 370
Los Angeles, California 90024
Telephone: [phone]
Facsimile: [phone]
Michael F. Ram, SBN 104805
[e-mail]
J. Kirk Boyd, SBN 122759
[e-mail]
RAM, OLSON, CEREGHINO & KOPCZYNSKI
555 Montgomery Street, Suite 820
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff,
RANDY BOYSEN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RANDY BOYSEN, an individual, on his
own behalf and on behalf of all others
similarly situated,
Plaintiff,

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v.
WALGREEN CO., an Illinois
Corporation d.b.a. WALGREENS; and
DOES 1-10, inclusive,
Defendants.

CASE NO. 11-cv-06262-SI
CLASS ACTION
STIPULATION AND [PROPOSED]
ORDER MODIFYING HEARING
DATE AND BRIEFING DEADLINES
ON DEFENDANT’S MOTION TO
DISMISS AND MOTION TO STAY
Current Hearing Date: June 15, 2012
Proposed Hearing Date: July 20, 2012
Time: 9:00 a.m.
Courtroom 10, 19th Floor
The Honorable Susan Illston

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CASE NO. 11-cv-06262-SI: STIPULATION AND [PROPOSED] ORDER

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Pursuant to Local Rules 6-2 and 7-12, and for the reasons set forth in the

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accompanying Declaration of Tina Wolfson, Plaintiff Randy Boysen (“Plaintiff”) and

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Defendant Walgreen Co. (“Defendant”) hereby stipulate, and request that the Court

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issue the [Proposed] Order below, to modify the hearing date and the briefing schedule

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on Defendant’s Motion to Dismiss (Docket No. 14) and Motion to Stay (Docket No.

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18) (collectively, the “Motions”), as follows:

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• Plaintiff’s Oppositions to the Motions, currently due on May 21 (14 days

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after service and filing per Local Rule 7-3), shall be due on June 4, 2012.

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• Defendant’s Replies in Support of the Motions, currently due May 28 (7 days

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after the Oppositions are filed and served), shall be due on June 18, 2012.

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• The currently noticed hearing date on both Motions, of June 15, 2012, shall
be extended to July 20, 2012.

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Dated:

May 17, 2012

/s/ Tina Wolfson
Tina Wolfson, Esq.
10850 Wilshire Blvd., Suite 370
Los Angeles, California 90024
Tel: [phone]; Fax: [phone]

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AHDOOT & WOLFSON, PC

Dated:

May 17, 2012

RAM, OLSON, CEREGHINO &
KOPCZYNSKI LLP
/s/ Michael F. Ram
Michael F. Ram, Esq.
555 Montgomery Street, Suite 820
San Francisco, California 94111
Tel: [phone]; Fax: [phone]
Attorneys for Plaintiff, Randy Boysen

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CASE NO. 11-cv-06262-SI: STIPULATION AND [PROPOSED] ORDER

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Dated:

May 17, 2012

MORRISON & FOERSTER

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By:

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/s/ James Schurz
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James M. Schurz
425 Market Street
San Francisco, California 94105
T: [phone]; F: [phone]
Email: [e-mail]
Attorneys for Defendant,
WALGREEN CO.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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5/18/12

By:

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The Honorable Susan Illston
U.S. District Court Judge

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ATTESTATION OF FILER
Pursuant to N.D. Cal. General Order No. 45 § X.B, the undersigned attests that
each of the above-named signatories concur in the filing of this Joint Motion.

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By:

/s/ Tina Wolfson
Tina Wolfson

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CASE NO. 11-cv-06262-SI: STIPULATION AND [PROPOSED] ORDER

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Tina Wolfson, SBN 174806
[e-mail]
Robert Ahdoot, SBN 172098
[e-mail]
AHDOOT & WOLFSON, P.C.
10850 Wilshire Boulevard, Suite 370
Los Angeles, California 90024
Telephone: [phone]
Facsimile: [phone]
Michael F. Ram, SBN 104805
[e-mail]
J. Kirk Boyd, SBN 122759
[e-mail]
RAM, OLSON, CEREGHINO & KOPCZYNSKI
555 Montgomery Street, Suite 820
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff,
RANDY BOYSEN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RANDY BOYSEN, an individual, on his
own behalf and on behalf of all others
similarly situated,

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Plaintiff,
v.
WALGREEN CO., an Illinois
Corporation d.b.a. WALGREENS; and
DOES 1-10, inclusive,
Defendants.

CASE NO. 11-cv-06262-SI
CLASS ACTION
DECLARATION OF TINA
WOLFSON IN SUPPORT OF
STIPULATION AND [PROPOSED]
ORDER MODIFYING HEARING
DATE AND BRIEFING DEADLINES
ON DEFENDANT’S MOTION TO
DISMISS AND MOTION TO STAY
Hearing Date: June 15th, 2012
Time: 9:00 a.m.
Courtroom 10, 19th Floor
The Honorable Susan Illston

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CASE NO. 11-cv-06262-SI: DECLARATION OF TINA WOLFSON

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I, Tina Wolfson, declare as follows:

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1.

I am an attorney duly licensed to practice in all courts in the State of

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California and the District of Columbia. Pursuant to Local Rule 6-2, I submit this

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declaration in support of the concurrently filed Stipulation and [Proposed] Order

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Modifying Hearing Date and Briefing Deadlines on Defendant’s Motion to Dismiss

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and Motion to Stay (the “Stipulation”) in the above-captioned case. The matters stated

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herein are true of my own knowledge or, where indicated, I am informed and believe

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that they are true. If called upon as a witness, I could and would competently testify to

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these facts.

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2.

My firm’s and my co-counsel’s firm’s extremely busy work schedules at

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this time, and the substantial work required to oppose Defendant’s Motion to Dismiss

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and Motion to Stay, make the originally scheduled briefing schedule and hearing date

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on these motions unmanageable for Plaintiffs’ counsel. Defendant’s counsel,

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meanwhile, is unavailable for another hearing date until July 20, 2012. Counsel for all

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parties have met and conferred on these scheduling issues, and agree that this proposed

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modification is fair and just under the circumstances.

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3.

There has been one previous time modification in this Action, by

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stipulation, which Extended the Deadlines in the Court’s Order Setting Initial Case

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Management Conference and ADR Deadlines. (Docket No. 8.)

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4.

The extension requested in the current Stipulation will have no effect on

the schedule for this case, other than requested briefing extension itself.

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I declare under the penalty of perjury on the 17th day of May, 2012, that the
foregoing is true and correct.

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Tina Wolfson

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CASE NO. 11-cv-06262-SI: DECLARATION OF TINA WOLFSON