Maridon v. Comcast Corporation

Filing 64

STIPULATION AND ORDER re 63 STIPULATION WITH PROPOSED ORDER re 57 Proposed Order, 56 Declaration in Support, 55 Declaration in Support, 50 Declaration in Support, 53 Declaration in Support, 51 Declaration in Support, 54 D eclaration in Support, 52 Declarati filed by Geri Maridon, Set/Reset Deadlines as to 63 STIPULATION WITH PROPOSED ORDER re 57 Proposed Order, 56 Declaration in Support, 55 Declaration in Support, 50 Declaration in Support, 53 Declaration in Support, 51 Declaration in Support, 54 Declaration in Support, 52 Declarati, 49 MOTION for Summary Judgment Memorandum of Points and Authorities. Responses due by 12/18/2013. Replies due by 12/23/2013.. Signed by Judge Edward M. Chen on 11/27/13. (bpf, COURT STAFF) (Filed on 11/27/2013)

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Le Clerc & Le Clerc LLP

235 Montgomery Street, Suite 1019  San Francisco, CA 94104

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Stephen Danz (SB# 68318)
STEPHEN DANZ & ASSOCIATES
11661 San Vicente Blvd., Suite 500
Los Angeles, CA 90049
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Marianne C. Koepf, State Bar No. 191025
[e-mail]
Mark S. Spring, State Bar No. 155114
[e-mail]
CAROTHERS DISANTE &
FREUDENBERGER LLP
601 Montgomery Street, Suite 350
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

Christopher R. LeClerc, Esq. (SB# 233479)
LE CLERC & LE CLERC LLP
235 Montgomery Street, Suite 1019
San Francisco, CA 94104
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
GERI MARIDON

Attorneys for Defendant Comcast Cable
Communications Management, LLC,
erroneously sued herein as Comcast
Corporation

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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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GERI MARIDON, an individual,

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Plaintiff,
v.
COMCAST CABLE
COMMUNICATIONS MANAGEMENT,
LLC; and DOES 1-100, inclusive,

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Defendants.

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Case No. C 12-2109 EMC
STIPULATION AND [PROPOSED]
ORDER MODIFYING BRIEFING
SCHEDULE ON MOTION FOR
SUMMARY JUDGMENT

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STIPULATION AND [PROPOSED] ORDER
MARIDON V. COMCAST CORP., ET AL. (CASE NO. C 12-2109 EMC)

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RECITALS

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1. Whereas, on November 6, 2013, Defendant filed a motion for summary

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judgment/adjudication. (Docket # 49-57.)

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2. Whereas, on November 14, 2013, the Court continued the hearing date of that motion to

(Docket # 61.) In said Order, the Court set the new deadline for Plaintiff to file an

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opposition to the motion for summary judgment on December 11, 2013 and the new

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deadline for Defendant to file a reply brief on December 18, 2013. The Court also reset

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Le Clerc & Le Clerc LLP

permit Plaintiff to conduct six depositions of declarants in support of said motion.

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235 Montgomery Street, Suite 1019  San Francisco, CA 94104

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the hearing date for the motion for summary judgment on January 2, 2014.

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3. Whereas, the Parties have met and conferred and the soonest available date for defense

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counsel and four of the witnesses is December 3rd, 5th, 6th and 9th.

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4. Whereas, on November 19, 2013, the Court reset the hearing date for the motion on

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January 6, 2014 at 3:30 p.m. (Docket # 62.)

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5. Whereas, in light of the fact that the depositions will be so close to the opposition

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deadline, Plaintiff has requested that the Court modify the briefing schedule to permit

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more time between the depositions and the opposition deadline. Defendant does not

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object to this request as long as Defendant is provided with at least seven days to prepare

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its reply and the reply brief is due no later than December 23. In light of this, the

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Plaintiff makes this unopposed and stipulated request to the Court to amend the briefing

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schedule to permit Plaintiff to file an opposition on or before December 16, 2013, and to

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allow Defendant until on or before December 23, 2013 to file a reply brief.

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STIPULATION AND [PROPOSED] ORDER
MARIDON V. COMCAST CORP., ET AL. (CASE NO. C 12-2109 EMC)

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STIPULATION
Plaintiff requests and Defendant agrees stipulates, as follows: That the Court enter

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an Order amending the briefing schedule on Defendant’s motion for summary judgment (Docket

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# 49-57) such that Plaintiff’s deadline to file an opposition is December 16, 2013, and that the

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Court provide Defendant a reply briefing deadline of December 23, 2013. The hearing date shall

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remain the same at January 6, 2014 at 3:30 p.m.

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Dated: 11/22/2013

Le Clerc & Le Clerc LLP

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By: /s/ Christopher R. LeClerc
Christopher R. LeClerc, Esq.
Attorney for Plaintiff
GERI MARIDON

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Dated: 11/22/2013

Carothers DiSante & Freudenberger LLP

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By: /s/ Mark Spring
Mark Spring, Esq.
Attorney for Defendant
Comcast Cable Communications
Management, LLC

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GRANTS the stipulation. IT IS SO ORDERED.

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RT

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By: ______________________________
Hon. Edward M. Chen
UnitedPROVDistrict Court Judge
States ED

AP

dwa
Judge E

ER

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hen

rd M. C

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11/27/13

R NIA

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Dated:

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S DISTRICT
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Having reviewed the Stipulation of the Parties, good cause appearing, the Court hereby

LI

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UNIT
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Le Clerc & Le Clerc LLP

235 Montgomery Street, Suite 1019  San Francisco, CA 94104

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STIPULATION AND [PROPOSED] ORDER
MARIDON V. COMCAST CORP., ET AL. (CASE NO. C 12-2109 EMC)

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SIGNATURE ATTESTATION

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Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this

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document has been obtained from the other signatories.

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Dated: 11/22/2013

Le Clerc & Le Clerc LLP

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By: /s/ Christopher R. LeClerc
Christopher R. LeClerc, Esq.
Attorney for Plaintiff
GERI MARIDON

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Le Clerc & Le Clerc LLP

235 Montgomery Street, Suite 1019  San Francisco, CA 94104

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STIPULATION AND [PROPOSED] ORDER
MARIDON V. COMCAST CORP., ET AL. (CASE NO. C 12-2109 EMC)