Circle Click Media LLC v. Regus Management Group LLC et al

Filing 339

STIPULATION AND ORDER re #338 STIPULATION WITH PROPOSED ORDER re #337 Case Management Scheduling Order, filed by Regus Management Group LLC, Regus Business Centre LLC, Regus plc, HQ Global Workplaces LLC Case Management Statement due by 12/3/2015. Case Management Conference reset for 12/10/2015 09:30 AM in Courtroom 5, 17th Floor, San Francisco. Class Certification Motion Hearing set for 2/18/2016 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Signed by Judge Edward M. Chen on 11/10/15. (bpf, COURT STAFF) (Filed on 11/10/2015)

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BRYAN CAVE LLP
K. Lee Marshall, California Bar No. 277092
Meryl Macklin, California Bar No. 115053
Daniel Thomas Rockey, California Bar No. 178604
Stephanie Blazewicz, California Bar No. 240359
Tracy M. Talbot, California Bar No. 259786
560 Mission Street, 25th Floor
San Francisco, CA 94105
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendants
REGUS MANAGEMENT GROUP LLC, REGUS BUSINESS CENTRE LLC,
HQ GLOBAL WORKPLACES, LLC, and REGUS plc

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UNITED STATES DISTRICT COURT

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BRYAN CAVE LLP
560 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA 94105-2994

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NORTHERN DISTRICT OF CALIFORNIA

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CIRCLE CLICK MEDIA LLC, a California
limited liability company, METRO TALENT,
LLC, a California limited liability company;
and CTNY INSURANCE GROUP LLC, a
Connecticut limited liability company, on
behalf of themselves and all others similarly
situated,
Plaintiffs,

Case No.: 3:12-CV-04000-EMC
STIPULATION REGARDING BRIEFING
SCHEDULE FOR MOTION FOR CLASS
CERTIFICATION AND RESCHEDULING
OF CASE MANAGEMENT
CONFERENCE; [PROPOSED] ORDER

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v.
REGUS MANAGEMENT GROUP LLC, a
Delaware limited liability company, REGUS
BUSINESS CENTRE LLC, a Delaware
limited liability company; REGUS plc, a
Jersey, Channel Islands, public limited
company; HQ GLOBAL WORKPLACES
LLC, a Delaware limited liability company;
and DOES 1 through 50,

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Defendants.
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264580

STIPULATION TO REQUEST RESCHEDULING OF CMC

Case No. 3:12-CV-04000-EMC

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Pursuant to Civil Local Rules 6-2 and 7-12 and this Court’s Case Management Conference

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Order in Reassigned Case (ECF No. 337), Defendants Regus Management Group LLC, Regus

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Business Centre LLC, HQ Global Workplaces, LLC, and Regus plc (collectively “Defendants”)

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and Plaintiffs Circle Click Media LLC and CTNY Insurance Group LLC (together “Plaintiffs”),

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by and through their respective counsel of record, submit this stipulation to set a briefing schedule

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for Plaintiffs’ motion for class certification and to request the rescheduling of the case

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management conference currently set for November 17, 2015 at 9:30 a.m.

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BRYAN CAVE LLP
560 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA 94105-2994

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WHEREAS, on October 30, 2015, the Court issued an order denying without prejudice
Plaintiffs’ Motion for Class Certification and granting 30 days for Plaintiffs to file a new motion
for class certification (ECF No. 335);

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WHEREAS, Plaintiffs’ current deadline to file the new motion for class certification is
November 30, 2015;

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WHEREAS, on November 5, 2015, the Court issued a Case Management Conference

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Order in Reassigned Case, setting a case management conference for November 17, 2015 at 9:30

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a.m.;

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WHEREAS, lead counsel for Defendants, K. Lee Marshall, has a mediation scheduled for
November 17, 2015;
WHEREAS, Plaintiffs and Defendants have agreed to extend Plaintiffs’ deadline for filing
a new motion for class certification and the related briefing schedule;
WHEREAS, the Parties have not made a prior request to amend the briefing schedule for

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Plaintiffs’ renewed motion for class certification or to reschedule this case management

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conference;

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WHEREAS, the requested briefing schedule and new date for the case management
conference will not prejudice the Court or the parties;
IT IS HEREBY STIPULATED AND AGREED by the parties hereto, by and through their
respective counsel of record, as follows:
1.

The case management conference should be rescheduled for Thursday, December

10, 2015 at 9:30 a.m., or as soon thereafter as the Court deems appropriate.
264580
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STIPULATION TO REQUEST RESCHEDULING OF CMC

Case No. 3:12-CV-04000-EMC

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2.

Plaintiffs’ deadline to file a new motion for class certification is extended until

December 17, 2015.

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3.

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18, 2016.

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4.

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February 2, 2016.

Defendants’ opposition to the motion for class certification will be due on January

Plaintiffs’ reply in support of the motion for class certification will be due on

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Dated:

November 6, 2015

BRYAN CAVE LLP

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By:

/s/ Stephanie A. Blazewicz_________
Stephanie A. Blazewicz
Attorneys for Defendants

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Dated:

November 6, 2015

ARI LAW, P.C.
LAW OFFICES OF S. CHANDLER VISHER

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By:

/s/ Ali A. Aalei_________________
Ali A. Aalei
Attorneys for Plaintiffs

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I, Stephanie A Blazewicz, attest that the content of this document is acceptable to all
persons required to sign the document.

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/s/ Stephanie A. Blazewicz

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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264580

Judge E

Judge Edward M. Chen

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11/10/15

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Date:

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The hearing on the Motion for
Class Certification is set for
2/18/16 at 1:30 p.m.

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UNIT
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BRYAN CAVE LLP
560 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA 94105-2994

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STIPULATION TO REQUEST RESCHEDULING OF CMC
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D IS T IC T
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Case No. 3:12-CV-04000-EMC