Ligon v. L'oreal USA, Inc.

Filing 20

JOINT STIPULATION AND ORDER RE 19 EXTENDING TIME TO RESPOND TO THE COMPLAINT AND CONTINUING CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES. Initial Case Management Conference set for 3/21/2013 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 1/22/13. (cl, COURT STAFF) (Filed on 1/22/2013)

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C. Brandon Wisoff (State Bar No. 121930)
[e-mail]
Benjamin J. Sitter (State Bar No. 273394)
[e-mail]
FARELLA BRAUN + MARTEL LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

Azra Z. Mehdi, Esq.
[e-mail]
The Mehdi Firm
One Market
Spear Tower, Suite 3600
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]

Frederick B. Warder III (admitted pro hac vice)
[e-mail]
PATTERSON BELKNAP WEBB & TYLER LLP
1133 Avenue of the Americas
New York, New York 10036
Telephone: [phone]
Facsimile: [phone]

Attorney for Plaintiff and the Proposed
Class

Attorneys for Defendant
L’ORÉAL USA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Ligon,

Case No. 3:12-cv-04585-RGS
Plaintiff,

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vs.

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L’Oréal USA, Inc.,

JOINT STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME TO
RESPOND TO THE COMPLAINT AND
CONTINUING CASE MANAGEMENT
CONFERENCE AND RELATED
DEADLINES

Defendant.

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Pursuant to Local Rule 6-2, Plaintiff Nancie Ligon (“Plaintiff) and Defendant L’Oréal

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USA, Inc. (“L’Oréal or Defendant”) hereby submit, through the undersigned, the following Joint

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Stipulation requesting a further extension of time for L’Oréal to respond the complaint and

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continuing for approximately 30 days the scheduled initial Case Management Conference and

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related deadlines.

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Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
[phone]

WHEREAS on August 30, 2012, Plaintiff filed her complaint in the above-titled action in
the United States District Court, Northern District of California;
WHEREAS on September 6, 2012, Plaintiff served her complaint on Defendant;
JOINT STIPULATION EXTENDING TIME
Case No. 3:12-cv-04585-RGS

28231\3510598.1

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WHEREAS Defendant's responsive pleading deadline was originally September 27, 2012,
but was extended by stipulation to November 16, 2012;
WHEREAS on October 15, 2012, the Court ordered a CMC to take place on January 17,
2013 at 10:00 a.m.;
WHEREAS on October 25, 2012, pursuant to stipulation, the Court further extended

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L’Oréal’s response deadline to January 29, 2013 and continued the CMC date to February 21,

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2013 to allow the parties time to engage in informal discovery and to discuss the claims and

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defenses;

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WHEREAS the parties are still engaging in informal discovery on a confidential basis and

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analyzing and discussing claims and defenses and would like the time to complete this process

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before moving forward with litigation;

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IT IS THEREFORE STIPULATED AND AGREED by and among Plaintiff and L’Oréal

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through the undersigned, to extend L’Oréal’s responsive pleading deadline to March 1, 2013, to

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postpone the CMC until March 21, 2013 at 10:00 a.m. , or until the first available date thereafter,

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and to continue all dates relating to the CMC accordingly.

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SO STIPULATED:

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Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
[phone]

JOINT STIPULATION EXTENDING TIME
Case No. 3:12-cv-04585-RGS

-2-

28231\3510598.1

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DATED: January 22, 2013.

FARELLA BRAUN + MARTEL LLP

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By:

/s/
C. Brandon Wisoff

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Attorneys for Defendant L’Oréal USA, Inc.
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DATED: January 22, 2013.

THE MEHDI FIRM

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By:

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/s/
Azra Z. Mehdi

Attorney for Plaintiff and the Proposed Class

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ATTESTATION PURSUANT TO CIVIL L.R. 5-1
I, Brandon Wisoff, am the ECF User whose ID and password are being used to file this

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Stipulation And Proposed Order. In compliance with Civil L.R. 5-1, I hereby attest that the

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concurrence in the filing of this document has been obtained from each of the signatories. I

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declare under penalty of perjury under the laws of the United States of America that the foregoing

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is true and correct.

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Executed this 22nd day of January 2013.

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/s/
C. Brandon Wisoff

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PURSUANT TO STIPULATION, IT IS SO ORDERED
DATED: January 22 2013.
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Hon. Richard Seeborg
United States District Judge

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Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
[phone]

JOINT STIPULATION EXTENDING TIME
Case No. 3:12-cv-04585-RGS

-3-

28231\3510598.1