Sharma et al v. BMW of North America LLC

Filing 181

STIPULATION AND ORDER RE: CLASS CERTIFICATION BRIEFING SCHEDULE. The briefing schedule is modified as follows. No later than December 2, 2016, plaintiff shall file his motion for class certification. No later than January 27, 2017, plaintiff shall produce his expert(s) for deposition. No later than March 6, 2017, defendant BMW of North America, Inc. shall file its opposition to the motion for class certification. No later than March 31, 2017, defendant shall produce its expert(s) for deposition. No later than April 24, 2017, plaintiff shall file his reply. The hearing on the motion is scheduled for May 26, 2017, at 9:00 a.m. Signed by Judge Maxine M. Chesney on 10/19/16. (mmclc2, COURT STAFF) (Filed on 10/19/2016)

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Squire Patton Boggs (US) LLP
Troy M Yoshino (State Bar # 197850)
[e-mail]
Eric J Knapp (State Bar # 214352)
[e-mail]
Aengus H Carr (State Bar # 240953)
[e-mail]
275 Battery Street, Suite 2600
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
BMW of NORTH AMERICA, LLC

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275 Battery Street, Suite 2600

NORTHERN DISTRICT OF CALIFORNIA

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San Francisco, California 94111

UNITED STATES DISTRICT COURT

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SQUIRE PATTON BOGGS (US) LLP

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SAN FRANCISCO DIVISION

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MONITA SHARMA and ERIC ANDERSON,
on behalf of themselves and all others similarly
situated,

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Plaintiffs,

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v.

Case No. 3:13-cv-02274-MMC
STIPULATION AND [PROPOSED]
ORDER RE: CLASS CERTIFICATION
BRIEFING SCHEDULE
Judge: Maxine M. Chesney

BMW OF NORTH AMERICA, LLC, a
Delaware Limited Liability Company,

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Defendant.
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Pursuant to Northern District of California Civil Local Rules 6-1(b), 6-2 and 7-12,

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Plaintiff Eric Anderson (“Plaintiff”) and Defendant BMW of North America, LLC (“BMW NA”

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or “Defendant”), by and through their respective attorneys, hereby stipulate as follows:
STIPULATION

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WHEREAS, on September 9, 2016, the Court entered an order setting a class certification
briefing schedule (Dkt. No. 179);
WHEREAS, the Parties are engaged in mediation and agree that it would be mutually
beneficial to allow for the mediation and related discussions to occur;

010-8275-4174/2/AMERICAS

STIPULATION AND [PROPOSED] ORDER
RE: CLASS CERTIFICATION BRIEFING
SCHEDULE 3:13-CV-02274-MMC

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NOW, THEREFORE, undersigned counsel for the Parties, having met and conferred,

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stipulate and agree that there is good cause for a modification to the upcoming case schedule as

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follows:

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1. December 2, 2016 – Plaintiff to file motion for class certification

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2. January 27, 2017 – Deadline for Plaintiff to produce his experts for deposition

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3. March 6, 2017 – BMW NA to file opposition to class certification motion

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4. March 31, 2017 – Deadline for BMW NA to produce its experts for deposition

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5. April 24, 2017– Plaintiff to file reply in support of class certification motion

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6. May 26, 2017 at 9:00 a.m. or as soon thereafter as the motion may be heard – Hearing

275 Battery Street, Suite 2600

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San Francisco, California 94111

SQUIRE PATTON BOGGS (US) LLP

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on Plaintiff’s motion for class certification
IT IS HEREBY STIPULATED.

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Dated: October 18, 2016

KERSHAW, COOK & TALLEY PC

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By: /s/ William A. Kershaw
William A. Kershaw

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Attorneys for Plaintiff and the putative Class

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Dated: October 18, 2016

SQUIRE PATTON BOGGS (US) LLP

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By:

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/s/ Troy M. Yoshino
Troy M. Yoshino

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Attorneys for Defendant
BMW of NORTH AMERICA, LLC

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Civil L.R. 5-1(i) Certification
The filing attorney hereby certifies that concurrence in the filing of the document has been obtained
from each of the other signatories, in full accordance with Civil Local Rule 5-1(i).

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-2010-8275-4174/2/AMERICAS

STIPULATION AND [PROPOSED] ORDER
RE: CLASS CERTIFICATION BRIEFING
SCHEDULE 3:13-CV-02274-MMC

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: ______________________
October 19, 2016

_______________________________
Honorable Maxine M. Chesney
SENIOR DISTRICT JUDGE
UNITED STATES DISTRICT COURT

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275 Battery Street, Suite 2600

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San Francisco, California 94111

SQUIRE PATTON BOGGS (US) LLP

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-3010-8275-4174/2/AMERICAS

STIPULATION AND [PROPOSED] ORDER
RE: CLASS CERTIFICATION BRIEFING
SCHEDULE 3:13-CV-02274-MMC