Myles v. AlliedBarton Security Services, LLC et al

Filing 36

STIPULATION AND ORDER RE BRIEFING SCHEDULE FOR SUMMARY JUDGMENT re 35 STIPULATION WITH PROPOSED ORDER. Dispositive motions to be heard by 6/4/2014. Pretrial Conference set for 7/14/2014 02:00 PM and Jury Trial set for 8/11/2014 08:30 AM, both in Courtroom 12, 19th Floor, San Francisco before Hon. William H. Orrick. Signed by Judge William H. Orrick on 11/12/2013. (jmdS, COURT STAFF) (Filed on 11/12/2013)

Jeremy T. Naftel, State Bar No. 185215
1 [e-mail]
Nicole A. Legrottaglie, State Bar No. 271416
2 [e-mail]
CAROTHERS DISANTE & FREUDENBERGER LLP
3 900 University Avenue
Suite 200
4 Sacramento, California 95825
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for Defendant
AlliedBarton Security Services, LP
7
Shaun Setareh (SBN 204514)
8 [e-mail]
SETAREH LAW GROUP
9 9454 Wilshire Blvd., Suite 711
Beverly Hills, California 90212
10 Telephone:
310.888.7771
Facsimile:
310.888.7771
11
Attorneys for Plaintiff
12 Joan Myles
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
JOAN MYLES, individually and on behalf of all ) Case No. C12-5761 WHO
others similarly situated,
)
) Assigned for All Purposes To:
Plaintiff,
) Judge: Hon. William H. Orrick
) Ctrm: 2
v.
)
) STIPULATION AND ORDER RE
ALLIEDBARTON SECURITY SERVICES,
) BRIEFING SCHEDULE FOR
LLC, a Delaware Limited Liability Company;
) SUMMARY JUDGMENT
ALLIED SECURITY HOLDINGS, LLC, a
)
Delaware Limited Liability company;
)
SPECTAGUARD ACQUISITION, LLC, a
)
Delaware Limited Liability company; and DOES )
1 through 100,
)
)
Defendants.
)
) Action Filed: November 9, 2012

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On September 3, 2013, this Court issued an order requiring that the parties file their cross

26 motions for summary judgment/adjudication in sufficient time to be heard no later than January 29,
27 2014, and that mediation be completed no later than January 29, 2014. Plaintiff Joan Myles
28 (“Plaintiff”) and Defendant AlliedBarton Security Services, LP (“Defendant”) hereby stipulate and
STIP & ORDER RE PROPOSED BRIEFING
1
SCHEDULE FOR SUMMARY JUDGMENT

751590.1

1 request that these deadlines be modified to permit the parties to complete mediation by
2 February 25, 2014 and to thereafter file their cross-motions for summary judgment on or before
3 April 25, 2014.
Good cause exists for the requested modifications in that the parties have worked diligently

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5 to select a mediator and secure a mediation date that is workable for both parties, their counsel, and
6 clients. With their best diligence, the first available date the parties were able to agree to for
7 mediation is February 25, 2014. That mediation has been scheduled with mediator Jeff Krivis for
8 that date. In an effort to allow the parties to complete mediation without incurring potentially
9 unnecessary costs associated with cross-motions for summary judgment, the parties request that
10 they be permitted to complete the mediation first and then have 60 days thereafter to file their
11 cross-motions for summary judgment.
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IT IS SO STIPULATED.
Dated: November 11, 2013

CAROTHERS DISANTE & FREUDENBERGER LLP

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By:

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Nicole A. Legrottaglie
Attorneys for Defendant
AlliedBarton Security Services, LP

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Dated: November 11, 2013

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/s/ Nicole A. Legrottaglie

SETAREH LAW GROUP
By:

/s/ Shaun Setareh
Shaun Setareh
Attorneys for Plaintiff Joan Myles

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ORDER

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Based on the stipulation of the parties, and good cause appearing therefor, IT IS HEREBY

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ORDERED that the case management deadlines are hereby modified to permit the parties to
complete mediation by February 25, 2014, and to thereafter file cross-motions for summary
judgment by April 25, 2014. In addition, the following dates are also modified:

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751590.1

STIP & ORDER RE PROPOSED BRIEFING
SCHEDULE FOR SUMMARY JUDGMENT

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Last Day for Hearing Dispositive Motions--June 4, 2014

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Final Pretrial Conference--July 14, 2014 at 2:00 p.m.

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Jury Trial--August 11, 2014 at 8:30 a.m.

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IT IS SO ORDERED.

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DATED: November 12, 2013

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Honorable William H. Orrick
United States District Court Judge

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751590.1

STIP & ORDER RE PROPOSED BRIEFING
SCHEDULE FOR SUMMARY JUDGMENT