Garrison et al v. Whole Foods Market California, Inc. et al

Filing 59

Order by Hon. Vince Chhabria granting 58 Stipulation for Limited Modification of the Scheduling Order.(knm, COURT STAFF) (Filed on 4/6/2015)

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SEYFARTH SHAW LLP
Jay W. Connolly (SBN 114725)
[e-mail]
Giovanna A. Ferrari (SBN 229871)
[e-mail]
Joseph J. Orzano (SBN 262040)
[e-mail]
560 Mission Street, 31st Floor
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
WHOLE FOODS MARKET CALIFORNIA, INC. and
MRS. GOOCH’S NATURAL FOOD MARKETS,
INC.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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MARY GARRISON and GRACE
GARRISON, individually, and on behalf of all
others similarly situated,

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Plaintiffs,
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Case No. 3:14-CV-00334-VC
STIPULATION AND [PROPOSED]
ORDER FOR LIMITED
MODIFICATION TO SCHEDULING
ORDER

v.
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WHOLE FOODS MARKET CALIFORNIA,
INC., et al.,
Defendants.

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Pursuant to Local Rule 6-1(b), Plaintiffs MARY GARRISON and GRACE GARRISON,

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individually, and on behalf of all others similarly situated (collectively “Plaintiffs”), on the one

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hand, and Defendants WHOLE FOODS MARKET CALIFORNIA, INC. and MRS. GOOCH’S

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NATURAL FOOD MARKETS, INC. (collectively “Defendants”), by and through their

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undersigned counsel, hereby stipulate as follows:

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WHEREAS, on March 18, 2015, the Court ordered that the Parties submit a stipulated

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ESI Protocol on or before March 24, 2015 to the extent the Parties were able to reach an

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agreement by that time. To the extent the Parties did not reach an agreement by that time, the

Stipulation to Modify Scheduling Order and [Proposed] Order / Case No. 3:14-cv-00334-VC

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Court ordered the Parties to provide an update to the Court in their Updated Joint Case

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Management Conference Statement.

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WHEREAS, in the Parties Joint Updated Case Management Conference Statement, the

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Parties indicated that they would be prepared to file a joint letter brief as to their dispute

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regarding the development of a stipulated ESI Protocol on or before April 3, 2015.

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WHEREAS, at the March 31, 2015 case management conference, the Parties discussed

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with the Court their subsequent efforts to confer and agreed to file an ESI Protocol or joint letter

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brief regarding any outstanding dispute as to the development of an ESI Protocol on or before

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April 10, 2014.

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WHEREAS, the Court requested the Parties submit a stipulation documenting the agreed
proposal.

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IT IS THEREFORE STIPULATED that:

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1.

Instead of filing a joint letter brief to the Court on or before April 3, 2015, the

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Parties shall submit a stipulated ESI Protocol or joint letter brief as to any issues in dispute

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regarding the development of an ESI Protocol on or before April 10, 2015.

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2.

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IT IS SO STIPULATED.

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All other deadlines remain unchanged.

DATED: April 2, 2015

SEYFARTH SHAW LLP

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By: /s/ Joseph J. Orzano
Jay W. Connolly
Giovanna A. Ferrari
Joseph J. Orzano

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Attorneys for Defendants
WHOLE FOODS MARKET CALIFORNIA,
INC. and MRS. GOOCH’S NATURAL FOOD
MARKETS, INC.

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Stipulation to Modify Scheduling Order and [Proposed] Order / Case No. 3:14-cv-00334-VC

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DATED: April 2, 2015

SCOTT COLE & ASSOCIATES, APC

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By: /s/ Molly A. Desario
Matthew R. Bainer
Molly a. DeSario

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Attorneys for Plaintiffs
MARY GARRISON and GRACE
GARRISON, individually and on behalf of all
other similarly situated

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
1.

Instead of filing a joint letter brief to the Court on or before April 3, 2015, the

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Parties shall submit a stipulated ESI Protocol or joint letter brief as to any issues in dispute

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regarding the development of an ESI Protocol on or before April 10, 2015.

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2.

All other deadlines remain unchanged.

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April 6, 2015
DATED: _________________
HON. VINCE CHHABRIA
United States District Court Judge

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19551034v.1

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Stipulation to Modify Scheduling Order and [Proposed] Order / Case No. 3:14-cv-00334-VC