Ehret v. Uber Technologies, Inc.

Filing 98

STIPULATION AND ORDER re 97 STIPULATION WITH PROPOSED ORDER Stipulation and [Proposed] Order Re Class Certification Briefing Schedule filed by Caren Ehret Further Case Management Conference set for 10/8/2015 01:30 PM in Courtroom 5, 17th Floor, San Francisco. Motion Hearing set for 10/8/2015 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen.. Signed by Judge Edward M. Chen on 3/30/15. (bpf, COURT STAFF) (Filed on 3/30/2015)

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Myron M. Cherry (California State Bar No. 50278)
[e-mail]
MYRON M. CHERRY & ASSOCIATES LLC
30 North LaSalle Street, Suite 2300
Chicago, Illinois 60602
Telephone: [phone]
Facsimile: [phone]
Hall Adams (admitted pro hac vice)
[e-mail]
LAW OFFICES OF HALL ADAMS, LLC
33 North Dearborn Street, Suite 2350
Chicago, Illinois 60602
Telephone: [phone]
Facsimile: [phone]

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Michael F. Ram (SBN 104805)
[e-mail]
Karl Olson (SBN 104760)
[e-mail]
RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP
555 Montgomery Street, Suite 820
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiff and the Class

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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CAREN EHRET, individually and on behalf
of a class of similarly situated persons,

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Plaintiff,
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Case No. 3:14-cv-113-EMC
STIPULATION AND [PROPOSED]
ORDER RE CLASS CERTIFICATION
BRIEFING SCHEDULE

v.
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UBER TECHNOLOGIES, INC., a Delaware
Corporation.

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Defendant.

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Plaintiff Caren Ehret (“Plaintiff”) and Defendant Uber Technologies, Inc. (“Defendant” or

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“Uber”) (collectively, the “Parties”), by and through their attorneys of record, STIPULATE AS

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FOLLOWS:

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The current deadline for Plaintiff’s filing of a motion for class certification is April 16,
2015. The current deadline for Defendant’s filing of its opposition to Plaintiff’s motion for class

Case No. 3:14-cv-113-EMC – STIPULATION AND [PROPOSED] ORDER RE CLASS CERTIFICATION
BRIEFING SCHEDULE

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certification is May 21, 2015, and the current deadline for Plaintiff’s reply is June 18, 2015. The

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current deadline for the parties to file a case management statement is July 2, 2015. A case

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management conference and hearing on Plaintiff’s motion for class certification is currently

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scheduled for July 9, 2015.

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Due to the trial schedule of Defendant’s counsel, the parties have had to reschedule the

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mediation in this case. It is now set for June 29, 2015 with Martin Quinn. In the light of their

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intention to attempt to mediate this matter and in an effort to conserve the Court’s and the parties’

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resources, the parties respectfully request that the Court order as follows:

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The deadline for Plaintiff’s filing of a motion for class certification shall be extended to

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July 16, 2015. The deadline for Defendant’s filing of its opposition to Plaintiff’s motion for class

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certification shall be extended to August 20, 2015. The deadline for Plaintiff’s reply shall be

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extended to September 17, 2015. This is the third extension of the class certification deadlines.

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The deadline for the parties to file a case management statement shall be extended to

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October 1, 2015. The case management conference and hearing on Plaintiff’s motion for class

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certification shall be rescheduled for October 8, 2015 at 1:30 p.m.

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IT IS SO STIPULATED.
Dated: March 27, 2015

[e-mail]

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QUINN, EMANUEL, URQUHART
& SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
Telephone: [phone]
Attorneys for Defendant

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/s/ Arthur M. Roberts
Arthur M. Roberts (SBN 275272)

Dated: March 27, 2015

/s/ Michael F. Ram
Michael F. Ram (SBN 104805)
[e-mail]
RAM, OLSON, CEREGHINO
& KOPCZYNSKI LLP
555 Montgomery Street, Suite 820
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and the Class
**Filers Attestation: Pursuant to Civil L.R. 5-1(i)(3)
regarding signatures, Michael F. Ram hereby attests
that concurrence in the filing of this document has
been obtained from each Signatory.

Case No. 3:14-cv-113-EMC – STIPULATION AND [PROPOSED] ORDER RE CLASS CERTIFICATION
BRIEFING SCHEDULE

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ORDER

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GOOD CAUSE APPEARING, the Court hereby approves this Stipulation.

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IT IS SO ORDERED.
Dated:

3/30/15

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. Chen

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Judge E

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The Hon. Edward M. Chen
DERED
Judge, UnitedRStates District Court
IS SO O
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Case No. 3:14-cv-113-EMC – STIPULATION AND [PROPOSED] ORDER RE CLASS CERTIFICATION
BRIEFING SCHEDULE

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