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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GIBSON, DUNN & CRUTCHER LLP
ANDREW S. TULUMELLO (SBN 196484)
[e-mail]
1050 Connecticut Avenue, NW
Washington, DC 20036
Telephone: [phone]
Facsimile: 202.467.0539
Attorney for Defendant
Frito-Lay North America, Inc.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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MARKUS WILSON and DOUG
CAMPEN, individually and on behalf of all
others similarly situated,

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Plaintiffs,

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v.

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FRITO-LAY NORTH AMERICA, INC.,

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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

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STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME FOR DEADLINES
IN SCHEDULE
Case No. CV12-01586 - SC

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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: [phone]
Fax: [phone]
[e-mail]

/s/ Andrew S. Tulumello
Andrew S. Tulumello
GIBSON, DUNN & CRUTCHER, LLP
1050 Connecticut Ave., NW
Washington, DC 20036-5306
Telephone: [phone]
Fax: [phone]
[e-mail]

Attorney for Plaintiffs
Markus Wilson and Doug Campen

Attorney for Defendant
DISTRIC
Frito-LayES
T
T North America, Inc.

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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

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June 12, 2015

RT

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May 22, 2015

NO

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May 22, 2015

RT
U
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April 10, 2015

R NIA

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March 6, 2015

FO

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LI

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February 13, 2015
March 6, 2015

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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

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parties will be bound by the following schedule:

UNIT
ED

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C

N
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STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME FOR DEADLINES
D IS T IC T O
R
IN SCHEDULE
Case No. CV12-01586 – SC
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