Wilson v. Frito-Lay North America, Inc. et al

Filing 105

STIPULATION AND ORDER Regarding Extension of Time for Deadlines in Schedule. Motion Hearing set for 7/31/2015 10:00 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Samuel Conti. Signed by Judge Samuel Conti on 12/2/2014. (tmi, COURT STAFF) (Filed on 12/2/2014)

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1 2 3 4 5 6 GIBSON, DUNN & CRUTCHER LLP ANDREW S. TULUMELLO (SBN 196484) atulumello@gibsondunn.com 1050 Connecticut Avenue, NW Washington, DC 20036 Telephone: 202.955.8500 Facsimile: 202.467.0539 Attorney for Defendant Frito-Lay North America, Inc. 7 IN THE UNITED STATES DISTRICT COURT 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 SAN FRANCISCO DIVISION 10 11 12 MARKUS WILSON and DOUG CAMPEN, individually and on behalf of all others similarly situated, 13 Plaintiffs, 14 v. 15 FRITO-LAY NORTH AMERICA, INC., 16 17 18 19 20 21 22 23 24 25 26 27 Case No. 3:12-cv-01586-SC Modified STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME FOR DEADLINES IN SCHEDULE Judge: Hon. Samuel Conti Action Filed: April 5, 2012 Defendant. STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE The parties, through their undersigned counsel, hereby stipulate and agree as follows: WHEREAS, on October 15, 2014, this Court entered a Stipulation and Order Regarding Extension of time for Deadlines in Schedule, which did not waive the right of the parties to request or stipulate to further extensions (Dkt. No. 101); WHEREAS, though the parties have worked diligently in discovery and Frito-Lay has produced in excess of 100,000 pages of documents in response to discovery requests, the parties are still working to schedule and complete Rule 30(b)(6) and Rule 30(b)(1) depositions; and WHEREAS, the parties agree that additional time is necessary to complete Rule 30(b)(6), Rule 30(b)(1), and other individual and third-party depositions; The parties hereby STIPULATE and AGREE, subject to the Court’s approval, that the 28 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME FOR DEADLINES IN SCHEDULE Case No. CV12-01586 - SC 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 June 26, 2015 July 17, 2015 July 31, 2015 IT IS SO STIPULATED. Dated: November 26, 2014 Dated: November 26, 2014 /s/ David McMullan, Jr. David McMullan, Jr. (pro hac vice) DON BARRETT, P.A. 404 Court Square P.O. Box 927 Lexington, MS 39095 Telephone: (662) 834-2488 Fax: (662) 834-2628 dmcmullan@barrettlawgroup.com /s/ Andrew S. Tulumello Andrew S. Tulumello GIBSON, DUNN & CRUTCHER, LLP 1050 Connecticut Ave., NW Washington, DC 20036-5306 Telephone: (202) 955-8500 Fax: (202) 467-0539 ATulumello@gibsondunn.com Attorney for Plaintiffs Markus Wilson and Doug Campen Attorney for Defendant DISTRIC Frito-LayES T T North America, Inc. TA C 12/2/2014 ERED O ORD D IT IS S IFIE In accordance with N.D. Cal. Local Rule 5-1, Andrew S. MOD AS Tulumello attests that David McMullan, Jr. has consented to the filing of this document. onti amuel C Judge S /s/ Andrew S. Tulumello ER H 28 June 12, 2015 RT 27 May 22, 2015 NO 26 May 22, 2015 RT U O 23 April 10, 2015 R NIA 6 March 6, 2015 FO 5 LI 4 February 13, 2015 March 6, 2015 A 3 Deadline for Fact Discovery Date for Plaintiffs’ Class Certification Expert(s) Disclosures(s), ,Including Report(s), Declarations, and Evidence (if any) Date for Plaintiffs’ Motion for Class Certification and All Non-Expert Supporting Declarations, Evidence, and Any Other Supporting Materials Deposition of Plaintiffs’ Class Certification Expert(s) (if any) by Date for Frito-Lay’s Class Certification Expert(s) Disclosure(s), Including Reports (if any) Date for Frito-Lay’s Opposition to Plaintiffs’ Class Certification Motion Deposition of Frito-Lay’s Class Certification Expert(s) (if any) by Date for Plaintiffs’ Reply in Support of Class Certification Class Certification Hearing S 2 parties will be bound by the following schedule: UNIT ED 1 C N F STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME FOR DEADLINES D IS T IC T O R IN SCHEDULE Case No. CV12-01586 – SC 2

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