Ramirez v. Trans Union, LLC

Filing 55

STIPULATION AND ORDER AMENDING SCHEDULE FOR BRIEFING AND HEARING ON PENDING MOTIONS re 54 STIPULATION WITH PROPOSED ORDER filed by Sergio L. Ramirez. Reset Deadlines as to 51 MOTION to Disqualify Counsel And For Sanctions, 50 Interim MO TION to Appoint Counsel Pursuant to Fed. R. Civ. P. 23(g)(3), 52 MOTION to Dismiss for Lack of Jurisdiction. Responses due by 2/6/2013. Replies due by 2/20/2013. Motion Hearing set for 3/13/2013 at 9:00 AM in Courtroom F, 15th Floor, San Francisco before Magistrate Judge Jacqueline Scott Corley. Signed by Judge Jacqueline Scott Corley on January 16, 2013. (wsn, COURT STAFF) (Filed on 1/16/2013)

1 ANDREW J. OGILVIE (SBN 57932)
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CAROL M. BREWER (SBN 214035)
ANDERSON, OGILVIE & BREWER LLP
235 Montgomery Street, Suite 914
San Francisco, California 94104-3000
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

7 JOHN SOUMILAS (Pro hac vice)
8 FRANCIS & MAILMAN, P.C.

Land Title Building, 19th Floor
9 100 South Broad Street
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Philadelphia, PA 19110
Telephone: [phone]

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Attorneys for Plaintiff, Sergio L. Ramirez

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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

12-00632-JSC
Case No. CV-11-00180-CW (DMR)
STIPULATION AND [PROPOSED]
ORDER AMENDING SCHEDULE
FOR BRIEFING AND HEARING ON
PENDING MOTIONS

TRANS UNION, LLC,

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Defendant.
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WHEREAS, on January 9, 2013, defendant Trans Union, LLC (Trans Union)

23 filed its motions to disqualify opposing counsel and to dismiss for lack of
24 jurisdiction (Dkt 51 and 52) and plaintiff filed his motion for interim appointment
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of counsel (Dkt 50), hereinafter referred to as “the pending motions; ”
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Ramirez v. Trans Union LLC., N.D.Cal., Case no. 12-cv-00632 JSC
Stipulation and [Proposed] Order re Schedule for Briefing and Hearing on Pending Motions

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WHEREAS pursuant to the local rules and the Court’s prior scheduling

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order, the pending motions currently are scheduled for responsive papers to be filed

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by January 23, 2013, replies to be filed by January 30, 2013 and hearings on
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February 28, 2013;
WHEREAS, to allow the parties sufficient time to prepare their responses and

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7 replies and because Plaintiff’s counsel has a court hearing in another matter on the
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East Coast on February 28, 2013 and would be unable to attend both that hearing and
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the hearings on the pending motions under the current schedule;
WHEREAS, pursuant to Local Rules 6-1(b) and 6-2, the parties may request an

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12 order changing time that would affect the date of an event or deadline already fixed by
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Court order;

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WHEREAS this Stipulation is made in good faith and not for the purpose of

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16 delay;
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IT IS HEREBY STIPULATED, by and between the parties, through their
respective counsel of record, that:

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1.

The date for filing responses to the pending motions is continued from

21 January 23, 2013 to February 6, 2013;
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2.

The date for replies in support of the pending motions is continued from

January 30, 2013 to February 20, 2013;

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3.

The hearing date for the pending motions is continued from February

26 28, 2013 to March 14, 2013 at 9:00 AM in Courtroom F, 15th Floor, Federal Building,
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Ramirez v. Trans Union LLC., N.D.Cal., Case no. 12-cv-00632 JSC
Stipulation and [Proposed] Order re Schedule for Briefing and Hearing on Pending Motions

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1 450 Golden Gate Avenue, San Francisco, California.
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IT IS SO STIPULATED.

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Dated: January 15, 2013
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ANDERSON, OGILVIE & BREWER LLP
and
FRANCIS & MAILMAN, P.C.

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By

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/s/ Andrew J. Ogilvie
Andrew J. Ogilvie
Attorney for Plaintiff SERGIO L. RAMIREZ

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9 Dated: January 15, 2013
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STROOCK & STROOCK & LAVAN LLP
By

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

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[PROPOSED] ORDER

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Pursuant to stipulation, it is ORDERED that:
1.

The date for filing responses to Trans Union’s motions to disqualify

17 counsel and to dismiss and plaintiff’s motion for appointment as interim counsel (“the
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pending motions”) is continued from January 23, 2013 to February 6, 2013;

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2.

The date for filing replies in support of the pending motions is

21 continued from January 30, 2013 to February 20, 2013;

The hearing date for the pending motions is continued from February

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ER

R NIA

e Sco

FO

cquelin

LI

Judge Ja

H

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ERED

O ORD

Hon. Jacqueline Scott Corley
United States Magistrate oJudge
y
tt C rle
RT

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IT IS S

NO

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Dated: January 16 2013
__,

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ISTRIC
ES D
TC
AT
T

RT
U
O

28, 2013 to March 13, 2013 at 9:00 a.m..
14,

S

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3.

UNIT
ED

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N

F
D IS T IC T O
R

Ramirez v. Trans Union LLC., N.D.Cal., Case no. 12-cv-00632 JSC
Stipulation and [Proposed] Order re Schedule for Briefing and Hearing on Pending Motions

C

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