Brandon v. Safeway Inc.

Filing 30

ORDER, Motions terminated: 29 STIPULATION WITH PROPOSED ORDER EXTENDING DEADLINES RE DEFENDANT'S MOTION FOR SUMMARY JUDGMENT filed by Safeway Inc.. Signed by Judge Susan Illston on 11/30/12. (tfS, COURT STAFF) (Filed on 12/4/2012)

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ARNOLD & PORTER LLP
Monty Agarwal (191568)
Three Embarcadero Center, 7th Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: 415.471.3400
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 a schedule for Defendant Safeway Inc.’s Motion for Summary

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Judgment (“Motion”), as set forth in the Civil Pretrial Minutes issued on April 11, 2012 (Dkt. No.

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21).

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WHEREAS, the parties previously stipulated to, and the Court ordered, an extended briefing

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schedule, as set forth in the Stipulation and Order Extending Deadlines Re: Defendant’s Motion For

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Summary Judgment, issued on May 22, 2012 (Dkt. No. 25);

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WHEREAS, Plaintiff and Defendant jointly agree that a short continuance of 15 days to file
the Motion would allow the parties an opportunity to focus on completing an in progress effort
aimed at settling the matter;

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WHEREAS, the Parties have stipulated to a modified briefing schedule; and

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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
respective counsel, subject to approval of the Court as follows:
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The deadline by which Defendant must file the Motion is hereby extended up to and

including December 21, 2012;
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The deadline for Plaintiff’s opposition to the Motion is hereby extended up to and

including February 18, 2012;

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3.

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March 4, 2013;

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4.

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

The hearing on the Motion is hereby set for March 22, 2013, at 9:00 a.m., or as soon

thereafter as the Court’s schedule may allow;
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The undersigned Parties jointly and respectfully request that the Court enter this

Stipulation as an Order.

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

C 11-06614 SI

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Dated: November 28, 2012

ARNOLD & PORTER LLP

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

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Dated: November 28, 2012

FINKELSTEIN THOMPSON LLP

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By: /s/ Rosemary Rivas
Rosemary Rivas
Attorneys for Plaintiff

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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11/30/12
Dated: _________________________
Hon. Susan Illston
United States District Judge

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*

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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