Ramirez v. Trans Union, LLC

Filing 34

AMENDED ORDER by Magistrate Judge Jacqueline Scott Corley granting 32 Stipulation Modifying Briefing Schedule. The hearing is reset to October 10, 2012 at 9:00 a.m. (ahm, COURT STAFF) (Filed on 8/2/2012) (Entered: 08/02/2012).(ahm, COURT STAFF) (Filed on 8/2/2012)

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND (State Bar No. 83013)
STEPHEN J. NEWMAN (State Bar No. 181570)
BRIAN C. FRONTINO (State Bar No. 222032)
A. R. KACHADOORIAN (State Bar No. 240601)
JEFFREY B. BELL (State Bar No. 269648)
2029 Century Park East
Los Angeles, CA 90067-3086
Telephone: [phone]
Facsimile: 310-556-5959
Email: [e-mail]

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Attorneys for Defendant
TRANS UNION LLC

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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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SERGIO L. RAMIREZ, on behalf of himself
and all others similarly situated,
Plaintiff,

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v.
TRANS UNION, LLC,
Defendant.

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Case No. 3:12-cv-00632-JSC
[Assigned to the Honorable Jacqueline Scott
Corley]
AMENDED
STIPULATION AND [PROPOSED]
ORDER AMENDING BRIEFING
SCHEDULE

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STIPULATION AND [PROPOSED] ORDER
AMENDING BRIEFING SCHEDULE
Case No. 3:12-cv-00632-JSC
LA 51567056

WHEREAS, on August 1, 2012, defendant Trans Union, LLC (“Trans Union”) filed a

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Motion for Judgment on the Pleadings Pursuant to Fed. R. Civ. P. 12(c) and to Strike Pursuant to

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Fed. R. Civ. P. 12(f) (the “Motion”);
WHEREAS, pursuant to Civil Local Rule 7-3(a), the Opposition of plaintiff Sergio L.

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Ramirez (“Plaintiff”) to the Motion is due not later than August 15, 2012;
WHEREAS, pursuant to Civil Local Rule 7-3(c), Trans Union’s Reply in support of the

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Motion is due not later than August 22, 2012;
WHEREAS, the Motion is set for hearing on October 11, 2012;

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WHEREAS, to allow the parties sufficient time to prepare their Opposition and Reply

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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papers, and because Plaintiff’s counsel has a vacation scheduled for mid-August, the parties agree

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that a brief continuance of the foregoing dates is appropriate;

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WHEREAS, pursuant to Local Rules 6-1(b) and 6-2, the parties may request an order

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changing time that would affect the date of an event or deadline already fixed by Court order;
WHEREAS, the parties previously stipulated to the extension of the date by which Trans

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Union was required to respond to the initial Complaint on March 7, 2012, March 16, 2012 and

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March 29, 2012;

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WHEREAS, this Stipulation is made in good faith and not for purposes of delay;

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that:
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The date by which Plaintiff must file his Opposition to the Motion is continued from

August 15, 2012 to September 7, 2012;
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The date by which Trans Union must file its Reply in support of the Motion is

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continued from August 22, 2012 to September 21, 2012;

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//

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//

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//

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//
-1-

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STIPULATION AND [PROPOSED] ORDER
AMENDING BRIEFING SCHEDULE
Case No. 3:12-cv-00632-JSC
LA 51567056

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The hearing date on the Motion shall remain October 11, 2012.

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IT IS SO STIPULATED

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Dated: August 1, 2012

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND
STEPHEN J. NEWMAN
BRIAN C. FRONTINO
A. R. KACHADOORIAN
JEFFREY B. BELL

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By:
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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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/s/ Jeffrey B. Bell
Jeffrey B. Bell
Attorneys for Defendant
TRANS UNION LLC

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Dated: August 1, 2012

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ANDERSON, OGILVIE & BREWER, LLP
ANDREW J. OGILVIE
CAROL MCLEAN BREWER
FRANCIS & MAILMAN, P.C.
JOHN SOUMILAS

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By:

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/s/ John Soumilas
John Soumilas

Attorneys for Plaintiff
SERGIO L. RAMIREZ

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-2STIPULATION AND [PROPOSED] ORDER
AMENDING BRIEFING SCHEDULE
Case No. 3:12-cv-00632-JSC

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LA 51567056

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
August 2
Dated: ___________________, 2012

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__________________________________
Hon. Jacqueline Scott Corely
United States District Court Judge

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The hearing is reset for 10/10/12 at 9:00 a.m.

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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STIPULATION AND [PROPOSED] ORDER
AMENDING BRIEFING SCHEDULE
Case No. 3:12-cv-00632-JSC

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LA 51567056

DECLARATION OF JEFFREY B. BELL

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I, Jeffrey B. Bell, hereby declare as follows:

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I am admitted to practice before this Court and am associate at Stroock & Stroock &

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Lavan LLP (“Stroock”), counsel for defendant Trans Union, LLC in this action. I submit this

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Declaration in support of the Stipulation and [Proposed] Order Amending Briefing Schedule (the

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“Stipulation”), in accordance with Section X.B. of General Order 45 and Civil Local Rule 5-1(i)(3)

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of this Court. The facts set forth herein are true of my own personal knowledge. If called as a

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witness, I could and would competently testify thereto.
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On August 1, 2012, John Soumilas, counsel for plaintiff Sergio L. Ramirez,

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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contacted me by e-mail and approved the content of the Stipulation, which was sent to him for his

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review and approval on July 31, 2012, and authorizing me to execute it on his behalf.

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I declare under the penalty of perjury under the laws of the United States of America that
the foregoing is true and correct. Executed this August 1, 2012.

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/s/ Jeffrey B. Bell
Jeffrey B. Bell

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STIPULATION AND [PROPOSED] ORDER
AMENDING BRIEFING SCHEDULE
Case No. 3:12-cv-00632-JSC

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LA 51567056

CERTIFICATE OF SERVICE
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I hereby certify that on August 1, 2012, a copy of the foregoing STIPULATION AND

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[PROPOSED] ORDER AMENDING BRIEFING SCHEDULE was filed electronically and

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served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-

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mail to all parties by operation of the court’s electronic filing system or by mail to anyone unable to

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accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this

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filing through the court’s EM/ECF System.

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/s/ Jeffrey B. Bell
Jeffrey B. Bell

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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STIPULATION AND [PROPOSED] ORDER
AMENDING BRIEFING SCHEDULE
Case No. 3:12-cv-00632-JSC

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LA 51567056