Mendez v. C-Two Group, Inc.

Filing 38

STIPULATION AND ORDER re 37 STIPULATION WITH PROPOSED ORDER Stipulation to Continue Case Management Conference and [Proposed] Order filed by Jamie Madrigal Mendez Case Management Statement due by 7/17/2014. Initial Case Management Conference reset for 7/24/2014 09:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 4/28/14. (bpf, COURT STAFF) (Filed on 4/28/2014)

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Thomas A. Kearney, State Bar No. 90045
[e-mail]
Prescott W. Littlefield, State Bar No. 259049
[e-mail]
KEARNEY LITTLEFIELD LLP
633 W. Fifth Street, 28th Floor
Los Angeles, CA 90071
Telephone [phone]
Facsimile [phone]

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Gene J. Stonebarger, State Bar No. 209461
[e-mail]
Richard D. Lambert, State Bar No. 251148
[e-mail]
Elaine W. Yan, State Bar No. 277961
[e-mail]
STONEBARGER LAW
A Professional Corporation
75 Iron Point Circle, Suite 145
Folsom, CA 95630
Telephone [phone]
Facsimile [phone]

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Attorneys for Plaintiff Mendez and the Class

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JAMIE MENDEZ, an individual, on behalf
of herself and all others similarly situated

Case No.3:13-cv-05914-EMC

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Plaintiff,

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v.
C-TWO GROUP, INC.; MOBILESOTRM,
INC.; and DOES 1-50, inclusive,

STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
[PROPOSED] ORDER
Current Date: May 15, 2014
Current Time: 9:00 a.m.
Courtroom: 5, 17th Floor

Defendants.

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER

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TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

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Plaintiff Jamie Mendez and Defendant C-Two Group, Inc., by and through their

3 respective counsel of record, hereby stipulate as follows:
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WHEREAS, Plaintiff filed the Complaint in this Action in state court on November 5,

5 2013;
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WHEREAS, the Summons and Complaint were served on Defendants on November 21,

7 2014;
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WHEREAS, Defendants removed this Action to this Court on December 20, 2013;

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WHEREAS, this Action was assigned to this Court on January 9, 2014;

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WHEREAS, on March 11, 2014, this Court scheduled the Case Management Conference

11 for May 15, 2014;
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WHEREAS, Defendant C-Two Group, Inc. filed an Answer to Plaintiff’s First Amended

13 Class Action Complaint on March 14, 2014;
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WHEREAS, the Court’s Minutes from Defendant MobileStorm’s Motion to Dismiss

15 advises the parties that the Court intends to discuss ADR options at the Case Management
16 Conference currently set for May 15, 2014;
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WHEREAS, pursuant to the discussions between counsel, Plaintiff believes that it is

18 necessary to add additional parties that may be liable for some or all of Plaintiff’s allegations in
19 the First Amended Class Action Complaint;
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WHEREAS, Plaintiff is currently investigating the identities of all other potential parties

21 to this case in order to properly bring them before the Court prior to the Case Management
22 Conference;
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WHEREAS, it is Plaintiff’s belief that any discussion of ADR will be more productive

24 with all potentially liable parties before the Court;
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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER

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IT IS HEREBY STIPULATED pursuant to Local Rule 7-12 and the Court’s Civil

2 Standing Order that the Case Management Conference currently scheduled for May 15, 2014
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3 shall be continued for 63 days, to Thursday, July 17, 2014 at 9:30 a.m.
4 Dated: April 25, 2014
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KEARNEY LITTLEFIELD, LLP
STONEBARGER LAW, APC

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By: /s/ Richard D. Lambert
Richard D. Lambert
Attorneys for Plaintiff and the Class

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9 Dated: April 25, 2014
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WALSWORTH, FRANKLIN, BEVINS &
McCALL, LLP

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By: /s/ Laurie E. Sherwood
LAURIE E. SHERWOOD
ALEXANDER F. PEVZNER
Attorneys for Defendant
C-TWO GROUP, INC.

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I, Richard D. Lambert, hereby attest that pursuant to LR 5-1(i) I have on file concurrence for

17 any signatures indicated by a “conformed” signature (/s/) within this e-filed document.
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/s/ Richard D. Lambert
Richard D. Lambert

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RT

dward
Judge E

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DIF

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M. Che

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_________________________________
Hon. Edward M. Chen
United StatesERED Court Judge
RD District
S SO O IED
T INorthern District of California
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Dated:_________________

S DISTRICT
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C
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4/28/14

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PURSUANT TO STIPULATION, IT IS SO ORDERED. (modified)

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[PROPOSED] ORDER

UNIT
ED

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C
RN
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER
F
D IS T IC T O
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