Brandon v. Safeway Inc.

Filing 23

ORDER continuing motion from 10/12/12 to 1/18/13 @ 9 a.m., Motions terminated: 22 STIPULATION WITH PROPOSED ORDER Extending Deadlines Re: Defendant's Motion for Summary Judgment filed by Safeway Inc.. Motion Hearing set for 1/18/2013 09:00 AM in Courtroom 10, 19th Floor, San Francisco before Hon. Susan Illston.. Signed by Judge Susan Illston on 5/16/12. (tfS, COURT STAFF) (Filed on 5/17/2012)

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ARNOLD & PORTER LLP
Monty Agarwal (191568)
Rhonda S. Goldstein (250387)
Three Embarcadero Center, 7th Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: 415.471.3400
E-Mail: [e-mail]
E-Mail: [e-mail]
Attorneys for Defendant
SAFEWAY 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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LAWRENCE BRANDON, on behalf of
himself and all others similarly situated,

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Plaintiff,
v.

Case No.: C 11-06614 SI
STIPULATION AND [PROPOSED]
ORDER EXTENDING DEADLINES RE:
DEFENDANT’S MOTION FOR
SUMMARY JUDGMENT

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SAFEWAY INC., a Delaware corporation with
its Principal Place of Business in Pleasanton,
California.
Defendant.

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STIPULATION & [PROPOSED] ORDER EXTENDING DEADLINES
RE: DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

C 11-06614 SI

WHEREAS, at the Initial Case Management Conference (“CMC”) held in this action on

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April 6, 2012, the Court set the following schedule for Defendant Safeway Inc’s Motion for

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Summary Judgment (“Motion”), as set forth in the Civil Pretrial Minutes issued on April 11, 2012

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(Dkt. No. 21):

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Filing date: September 7, 2012

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Opposition due: September 21, 2012

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Reply due: September 28, 2012

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Hearing date: October 12, 2012 at 9:00 a.m.;
WHEREAS, at the April 6 CMC Plaintiff Lawrence Brandon and Defendant Safeway Inc.

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(collectively, the “Parties”) discussed with the Court that the Parties were discussing a potential

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mediation of the action, and intended to seek a modification to the schedule for the Motion in the

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event that they were able to agree to mediate;
WHEREAS, the Parties have reached an agreement to mediate the action on June 22, 2012,

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and therefore wish to extend the briefing schedule for the Motion by a period of ninety (90) days;

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and
WHEREAS, the agreed-upon schedule is not for the purpose of delay, promotes judicial

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efficiency and will not cause prejudice to any party;
THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the Parties, through their

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respective counsel, subject to approval of the Court as follows:
1.

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including December 6, 2012;
2.

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The deadline for Plaintiff’s opposition to the Motion is hereby extended up to and

including December 20, 2012;
3.

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The deadline by which Defendant must file the Motion is hereby extended up to and

The deadline for Defendant’s reply to the Motion is extended up to and including

December 27, 2012;
4.

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The hearing on the Motion is hereby set for January 18, 2013, at 9:00 a.m., or as

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soon thereafter as the Court’s schedule may allow;

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///
-1STIPULATION & [PROPOSED] ORDER EXTENDING DEADLINES
RE: DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

C 11-06614 SI

5.

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The undersigned Parties jointly and respectfully request that the Court enter this

Stipulation as an Order.

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Dated: May 11, 2012

ARNOLD & PORTER LLP

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By: /s/ Rhonda S. Goldstein*
Monty Agarwal
Rhonda S. Goldstein
Attorneys for Defendant
SAFEWAY INC.

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Dated: May 11, 2012

FINKELSTEIN THOMPSON LLP

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By: /s/ Danielle A. Stoumbos
Danielle A. Stoumbos
Attorneys for Plaintiff

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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5/16/12
Dated: _________________________
Hon. Susan Illston
United States District Judge

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*

I hereby attest that concurrence in the filing of this document has been obtained from each of the
other signatories.

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-2STIPULATION & [PROPOSED] ORDER EXTENDING DEADLINES
RE: DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

C 11-06614 SI