Joseph Duran et al v. The Hershey Company

Filing 42

STIPULATION AND ORDER RE 41 TO EXTEND CERTAIN DEADLINES. Case Management Conference set for 8/6/2015 at 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 5/19/15. (cl, COURT STAFF) (Filed on 5/19/2015)

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DARYL S. LANDY, State Bar No. 136288
MORGAN, LEWIS & BOCKIUS LLP
One Market, Spear Street Tower
San Francisco, CA 94105-1126
Tel: [phone]
Fax: [phone]
Email: [e-mail]
MICHAEL J. PUMA (admitted pro hac vice)
ELEANOR R. FARRELL (admitted pro hac vice)
MORGAN, LEWIS & BOCKIUS LLP
1701 Market Street
Philadelphia, PA 19103
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Counsel for Defendant The Hershey Company

THE BRANDI LAW FIRM
THOMAS J. BRANDI, SBN 53208
BRIAN J. MALLOY, SBN 234882
354 Pine Street, Third Floor
San Francisco, CA 94104
Telephone: [phone];
Facsimile: 415.707.2024
E-mail: [e-mail]
HOBAN & FEOLA, LLC
DAVID C. FEOLA (CO Bar No. 18789)
(admitted pro hac vice)
34523 Upper Bear Creek Road
Evergreen, Colorado 80439
Telephone: [phone]
Facsimile: 303.382.4685
E-mail: David @Feolalaw.com
Counsel for Plaintiffs

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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JOSEPH DURAN, JOHN BELL, JASON MEARS,
VICTOR DESIMONE, CHRISTINA LEE and
SARAH CATALDO,

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Plaintiffs,

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Case No. 3:14-CV-01184 RS
STIPULATION AND [PROPOSED]
ORDER TO EXTEND CERTAIN
DEADLINES
Hon. Richard Seeborg

vs.
THE HERSHEY COMPANY,
Defendant.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATION AND [PROPOSED] ORDER TO
EXTEND CERTAIN DEADLINES
CASE NO.: 3:14-CV-01184 RS

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Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiffs John Bell, Jason Mears, Victor

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DeSimone, and Christina Lee (“Plaintiffs”) and Defendant The Hershey Company (“Defendant”)

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(collectively, “Parties”), through their respective counsel of record, and subject to the approval of

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the Court, hereby stipulate as follows:

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1.

WHEREAS, on June 26, 2014, the Court issued a Case Management Order setting

certain deadlines (Dkt. No. 23);
2.

WHEREAS, on October 16, 2014 and January 1, 2015, the Court issued Orders

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approving the Parties’ stipulations to extend the mediation deadline and certain other deadlines in

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this matter (Dkt. Nos. 29 & 31);

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3.

WHEREAS, the Parties are actively engaged in discovery. The Parties have

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produced substantial documents, negotiated an ESI agreement, produced ESI pursuant to that

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agreement, Defendant has taken the depositions of all Plaintiffs, and Plaintiffs have scheduled the

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depositions of Defendant’s witnesses; two of which will need to be taken after the close of the

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June 15, 2015 fact discovery deadline, and including one on June 17, 2015 in San Francisco;

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4.

WHEREAS, Plaintiffs disclosed an economic damages expert report on May 14,

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2015 and, for the convenience of the parties and to save on expenses, Plaintiffs experts’ are

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available for deposition on June 16, 2015;

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5.

WHEREAS, Defendant has a conflict with the case management conference that

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was rescheduled for June 25, 2015 and the parties have agreed to move the case management

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conference deadline to August 6, 2015;

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6.

THEREFORE, the Parties hereby agree and stipulate to the extension of these four

deadlines as follows:
Event
Supplemental and Rebuttal
Expert Disclosures
Close of Expert Discovery

Current Deadline
June 4, 2015

Proposed Deadline
July 1, 2015

June 15, 2015

July 15, 2015

Deadline to take the
depositions of Mark Parlin
and Greg Welte

June 15, 2015 (close of fact
discovery)

June 17, 2015

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER TO
EXTEND CERTAIN DEADLINES
CASE NO.: 3:14-CV-01184 RS

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Case Management
Conference

June 25, 2015

August 6, 2015

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: May 19, 2015.

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MORGAN, LEWIS & BOCKIUS LLP
DARYL S. LANDY
MICHAEL J. PUMA
ELEANOR R. FARRELL
By:

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/s/Michael J. Puma
Michael J. Puma
Attorneys for Defendant
THE HERSHEY COMPANY

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DATED: May 19, 2015.

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BRANDI LAW FIRM
THOMAS J. BRANDI
BRIAN J. MALLOY

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HOBAN & FEOLA, LLC
DAVID C. FEOLA

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/s/ Brian J. Malloy
Brian J. Malloy

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Attorneys for Plaintiffs

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By:

PURSUANT TO STIPULATION, IT IS SO ORDERED.

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5/19 /15
DATED: ___________________
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Hon. Richard Seeborg
United States District Court Judge

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER TO
EXTEND CERTAIN DEADLINES
CASE NO.: 3:14-CV-01184 RS