Baker v. Bayer HealthCare Pharmaceuticals Inc.

Filing 57

STIPULATION AND ORDER to Continue Case Management Conference. Case Management Statement due by 10/20/2014. Further Case Management Conference set for 10/27/2014 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 09/02/2014. (tmi, COURT STAFF) (Filed on 9/2/2014)

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William M. Audet (SBN: 117456)
Mark E. Burton, Jr. (SBN: 178400)
Jill T. Lin (SBN: 284962)
AUDET & PARTNERS, LLP
221 Main Street, Suite 1460
San Francisco, California 94105
Telephone:
415.568.2555
Facsimile:
415.568.2556

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Attorneys for Plaintiff Nicole Baker
Alicia J. Donahue (SBN 117412)
Amir Nassihi(SBN 235936)
SHOOK, HARDY & BACON L.L.P.
One Montgomery, Suite 2700
San Francisco, California 94104
Telephone: [phone]
Facsimile: 415.391.0281
Attorneys for Defendant
BAYER HEALTHCARE
PHARMACEUTICALS INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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NICOLE BAKER,

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Case No. 3:13-cv-00490-TEH
Plaintiff,

v.

STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE

BAYER HEALTHCARE
PHARMACEUTICALS, INC.,
Defendant.

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Honorable Thelton E. Henderson

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Pursuant to Paragraph 4 of the Civil Standing Orders of the Honorable Thelton E. Henderson

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and Rule 7-12 of the Civil Local Rules for the United States District Court for the Northern District

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of California, Plaintiff Nicole Baker (“Plaintiff”) and Defendant Bayer HealthCare Pharmaceuticals

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Inc. (“Defendant”) (collectively referred to as the “Parties”) through their respective counsel hereby

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STIPULATION AND [PROPOSED] ORDER
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submit this stipulated request to continue the October 6, 2014 case management conference in this

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matter to October 27, 2014, or any other later date convenient for the Court’s calendar.

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This stipulated request is based upon the fact that defense counsel had a longstanding pre-

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booked East Coast trip for a client meeting and will not be able to attend the October 6, 2014 case

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management conference. The Parties recently filed stipulation and proposed order to continue the

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case management conference to October 14, 2014, to allow time for parties to work on resolving

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their ongoing discovery disputes. (Dkt. 54) However, the Court scheduled the conference to

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October 6, 2014, a date in conflict with defense counsel’s prior pre-booked travel arrangements to

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the East Coast.

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The Parties are in the process of finalizing a Joint Discovery Letter outlining each side’s

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position pertaining to Plaintiff’s complaints regarding Defendant’s production of documents as it

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relates to adverse event reports and sales call notes.

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Accordingly, the Parties respectfully request that this Court continue the October 6, 2014

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Case Management Conference to October 27, November 3, November 10, 2014, or to a later date

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more convenient to the Court’s calendar.

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties through
their respective attorneys of record that:

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1. The October 6, 2014 case management conference is continued to October 27, 2014,

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November 3, November 10, or to a later date convenient to the Court’s calendar; and

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2. The relevant deadlines under Rule 26 of the Federal Rules of Civil Procedure and Civil

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Local Rule 16-9 are continued to track the new date for the case management conference.

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Dated: August 29, 2014

By:

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Attorneys for Plaintiff
Nicole Baker

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/s/ Jill T. Lin
Jill T. Lin

//
//

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STIPULATION AND [PROPOSED] ORDER
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Dated: August 29, 2014

By:

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/s/ Alicia J. Donahue
Alicia J. Donahue

Attorneys for Defendant
Bayer HealthCare Pharmaceuticals Inc.

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Pursuant to L.R. 5-11(i)(3), I attest that concurrence in the filing of this document has been obtained

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from the other signatories.

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By:

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/s/ Alicia J. Donahue
Alicia J. Donahue

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STIPULATION AND [PROPOSED] ORDER
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[PROPOSED] ORDER

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The Court hereby orders that the case management conference currently set for October 6,

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2014 is continued to October 27, 2014, November 3, November 10, or to a later date convenient to

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the Court’s calendar. The relevant deadlines under Rule 26 of the Federal Rules of Civil Procedure

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and Civil Local Rule 16-9 are continued to track the new date for the case management conference.

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IT IS SO ORDERED.

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09/02/2014
Dated: ____________________

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__________________________________________
THE HONORABLE THELTON E. HENDERSON
U.S. DISTRICT COURT JUDGE

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STIPULATION AND [PROPOSED] ORDER
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