McKinnon v. Dollar Thrifty Automotive Group, Inc. et al

Filing 75

STIPULATION AND ORDER Extending Time for Briefing and Hearing on Motion for Protective Order. Set/Reset Deadlines as to 66 MOTION for Protective Order. Responses due by 7/26/2013. Replies due by 8/9/2013. Motion Hearing set for 8/23/2013 10:00 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Samuel Conti. Signed by Judge Samuel Conti on 07/18/2013. (tmi, COURT STAFF) (Filed on 7/18/2013)

1 WHATLEY KALLAS, LLP
Alan M. Mansfield (Of Counsel)
2 (SBN 125998)
[e-mail]
3 1 Sansome Street, 35th Floor, PMB #131
San Francisco, CA 94104
4 Tel: [phone]
Fax: [phone]
5
10200 Willow Creek Rd., Ste. 160
6 San Diego, CA 92131
Tel: [phone]
7 Fax: [phone]
WHATLEY KALLAS, LLP
8 Joe R. Whatley, Jr.
(Admitted Pro Hac Vice)
9 Patrick J. Sheehan
(Admitted Pro Hac Vice)
10 380 Madison Avenue, 23rd Floor
New York, NY 10017
11 Tel: [phone]
Fax: [phone]
12
Attorneys for Plaintiffs
13
UNITED STATES DISTRICT COURT
14

NORTHERN DISTRICT OF CALIFORNIA

15

SAN FRANCISCO DIVISION

16 SANDRA McKINNON and KRISTEN
TOOL, individually and on behalf of all others
17 similarly situated,

Case No. 12-cv-04457- SC

18

JOINT STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
BRIEFING AND HEARING ON
DEFENDANTS’ MOTION FOR
PROTECTIVE ORDER; DECLARATION
OF ALAN M. MANSFIELD IN SUPPORT

19

Plaintiffs,
v.

DOLLAR THRIFTY AUTOMOTIVE
20 GROUP, INC. d/b/a DOLLAR RENT A CAR;
DOLLAR RENT A CAR, INC.; DTG
21 OPERATIONS, INC. d/b/a DOLLAR RENT
A CAR; and DOES 1-10, inclusive,
22
Defendants.
23
24
25
26

CLASS ACTION

Current Hearing Date: August 16, 2013
Time:
10:00 a.m.
Judge:
Hon. Samuel Conti
Courtroom:
1
Proposed New Date: August 23, 2013
Time:
10:00 a.m.
[Complaint Filed: August 24, 2012]

27
28

-1SSTIPULATION TO EXTEND TIME FOR BRIEFING AND HEARING
ON DEFTS’ MOTION FOR PROTECTIVE ORDER; DECL. IN SUPPORT

Case No. 12-cv-04457-SC

1

Pursuant to Fed. R. Civ. P. 15(b)(4), Fed. R. Civ. P. 16(b)(4), and Civil L.R. 7-12, 6-1(b)

2 and 6-2, and the Declaration of Alan M. Mansfield, it is hereby stipulated by and between the
3 parties, through their respective counsel, as follows:
4

WHEREAS, on June 28, 2013, Defendants filed a Motion for Protective Order relating to

5 certain outstanding discovery pursuant to Federal Rule of Civil Procedure 26 (Dkt. No. 66);
6

WHEREAS, on July 8, 2013, the parties filed a Joint Stipulation and Proposed Order to

7 Extend Time for Briefing and Hearing on Defendants’ Motion for Protective Order. (Dkt. No.
8 69);
9

WHEREAS, on July 9, 2013, the Court entered the parties’ proposed order. (Dkt. No. 70).

10 Under the Court’s new Order, Plaintiffs’ opposition papers were due on or before July 19, 2013,
11 and Defendants’ reply papers in support of their motion were due on or before August 2, 2013.
12 Furthermore, the hearing on Defendants’ motion was continued to August 16, 2013 at 10:00 a.m.,
13 before this Court unless the motion was assigned to a Magistrate Judge for consideration;
14

WHEREAS, in order to continue their on-going discussions to determine if agreement can

15 be reached on the expeditious and efficient handling of initial discovery, the parties wish to extend
16 the schedule as follows:
17

Plaintiffs’ opposition papers in response to Defendants’ Motion for Protective Order shall

18 be due on or before July 26, 2013;
19

Defendants’ reply papers in support of their Motion for Protective Order shall be due on or

20 before August 9, 2013; and
21

The present hearing date on Defendants’ Motion for Protective Order shall be continued to

22 August 23, 2013 at 10:00 a.m., before this Court unless the motion is assigned to a Magistrate
23 Judge for consideration;
24

WHEREAS, the parties will promptly inform the Court if an agreement is reached that

25 moots Defendants’ Motion for Protective Order.
26 / / /
27 / / /
28

-2SSTIPULATION TO EXTEND TIME FOR BRIEFING AND HEARING
ON DEFTS’ MOTION FOR PROTECTIVE ORDER; DECL. IN SUPPORT

Case No. 12-cv-04457-SC

1

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED THAT the parties

2 agree to the above briefing schedule regarding Defendants’ Motion for Protective Order.
3 Dated: July 17, 2013

WHATLEY KALLAS LLP

4

/s/ Alan M. Mansfield
ALAN M. MANSFIELD
[e-mail]
1 Sansome Street, 35th Floor, PMB #131
San Francisco, CA 94104
Tel: [phone]
Fax: [phone]
10200 Willow Creek Rd., Ste 160
San Diego, CA 92131
Tel: [phone]
Fax: [phone]
By:

5
6
7
8
9
10

JOE R. WHATLEY JR. (Admitted Pro Hac Vice)
[e-mail]
PATRICK J. SHEEHAN (Admitted Pro Hac Vice)
[e-mail]
380 Madison Avenue, 23rd Floor
New York, NY 10017
Tel: [phone]
Fax: [phone]

11
12
13
14

Attorneys for Plaintiffs SANDRA McKINNON and
KRISTEN TOOL

15
16
17 Dated: July 17, 2013

JJENNER & BLOCK LLP

18

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/s/ John F. Ward, Jr.
JOHN F. WARD, JR.
ROSS B. BRICKER (Admitted Pro Hac Vice)
[e-mail]
JOHN F. WARD, JR. (Admitted Pro Hac Vice)
[e-mail]
JENNER & BLOCK LLP
353 N. Clark Street
Chicago, IL 60654-3456
Telephone:
312-222-9350
Facsimile:
312-527-0484
By:

N

D IS T IC T
R

OF

C

KENNETH E. KELLER (State Bar No. 71450)
[e-mail]
TRACY M. CLEMENTS (State Bar No. 184150)
[e-mail]
-3-

SSTIPULATION TO EXTEND TIME FOR BRIEFING AND HEARING
ON DEFTS’ MOTION FOR PROTECTIVE ORDER; DECL. IN SUPPORT

Case No. 12-cv-04457-SC