Wilson v. Walt Disney Company,

Filing 30

Order by Hon. Vince Chhabria granting 26 Stipulation to Modify Case Management Conference Hearing and Related Deadlines.(knm, COURT STAFF) (Filed on 6/9/2014)

1 J. Paul Gignac (State Bar No. 125676)
[e-mail]
2 Mischa N. Barteau (State Bar No. 274474)
[e-mail]
3
ARIAS OZZELLO & GIGNAC LLP
4 115 S. La Cumbre Lane, Suite 300
Santa Barbara, California 93105
5 Telephone:
[phone]
Facsimile:
[phone]
6
J.A. Ted Baer (State Bar No. 135092)
7
[e-mail]
8 LAW OFFICE OF J.A. TED BAER
21 E. Canon Perdido Street, Suite 223
9 Santa Barbara, California 93101
Telephone:
[phone]
10 Facsimile:
[phone]
11

Kelly M. Klaus (State Bar No. 161091)
[e-mail]
Jordan D. Segall (State Bar No. 281102)
[e-mail]
MUNGER, TOLLES & OLSON LLP
560 Mission Street, Twenty-Seventh Floor
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants

Attorneys for Plaintiff

12
13
UNITED STATES DISTRICT COURT

14

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

15
16
17

KELLY WILSON,
Plaintiff,

18
19

vs.

20 THE WALT DISNEY COMPANY, DISNEY
ENTERPRISES, INC., WALT DISNEY
21 PICTURES, and WALT DISNEY MOTION
PICTURES GROUP, INC.,
22
23

Case No. 3:14-cv-01441-VC
STIPULATION AND [PROPOSED]
ORDER TO MODIFY CASE
MANAGEMENT CONFERENCE,
HEARING AND RELATED DATES
Judge: Hon. Vince G. Chhabria

Defendants.

24
25
26
27
28
STIP. AND [PROPOSED] ORDER TO MODIFY CASE
MGMT. CONF., HEARING & RELATED DATES
3:14-CV-01441-VC

1

Plaintiff Kelly Wilson (“Plaintiff”) and Defendants The Walt Disney Company; Disney

2 Enterprises, Inc.; Walt Disney Pictures, and Walt Disney Motion Pictures Group, Inc.
3 (“Defendants”), by and through their respective counsel of record, hereby declare and stipulate as
4 follows:
5

WHEREAS, on May 12, 2014 the Court ordered that a Case Management Conference will

6 be held in this case on June 27, 2014, and ordered the parties to file a Joint Case Management
7 Statement and Proposed Case Management Order no later than seven calendar days before that
8 conference;
9

WHEREAS, on June 2, 2014, Defendants moved to dismiss Plaintiff’s complaint and

10 noticed the hearing on that motion for July 10, 2014 [Docket No. 22];
11

WHEREAS, pursuant to Civil Local Rule 6-2(a)(1), the parties state that the time

12 modifications set forth below are requested for the following reason:
13

The parties have agreed to stipulate to modify the date of the hearing on the motion to

14 dismiss because Plaintiff’s counsel is unavailable on July 10, 2014, and the Court is unavailable
15 the following Thursday, July 17, 2104. The parties have further agreed to stipulate to modify the
16 date of the Case Management Conference, subject to the Court’s schedule, to combine the hearing
17 date on the motion to dismiss and the Case Management Conference.
18

WHEREAS, pursuant to Civil Local Rule 6-2(a)(2), the parties disclose that there has been

19 one previous stipulated time modification in this case (May 6, 2014 [Docket No. 16]). This
20 stipulation extended the deadline for the Defendants to answer or otherwise respond to Plaintiff’s
21 complaint; and
22

WHEREAS, pursuant to Civil Local Rule 6-2(a)(3), the parties state that the requested

23 time modifications herein will not affect any other aspect of the case schedule;
24

ACCORDINGLY, THE PARTIES STIPULATE AS FOLLOWS:

25

(1)

The hearing on Defendants’ motion to dismiss will take place on July 24, 2014, at

26 10:00 a.m.
27

(2)

The Case Management Conference will take place on July 24, 2014, concurrently

28 with the hearing on the motion to dismiss.

1
STIP. AND [PROPOSED] ORDER TO MODIFY CASE
MBMT. CONF., HEARING & RELATED DATES
3:14-CV-01441-VC

1

(3)

The parties will meet and confer on the Joint Case Management Statement by July

2 3, 2014, and will file a Joint Case Management Statement and [Proposed] Case Management
3 Order by July 17, 2014, seven calendar days before the Case Management Conference.
4 Defendants will discuss with Plaintiffs the case management issues set forth in the Standing Order
5 for all Judges of the Northern District of California, but will request that initial disclosures
6 pursuant to Rule 26 and discovery be stayed pending resolution of the motion to dismiss, in an
7 effort to conserve party resources. Plaintiffs will meet and confer with Defendants on such
8 request.
9

(4)

The deadline for Plaintiff to file a brief in opposition to Defendants’ motion to

10 dismiss is extended to June 27, 2014.
11

(5)

The deadline for Defendants to file a reply brief in support of their motion to

12 dismiss is extended to July 10, 2014.
13

IT IS SO STIPULATED.

14
15 DATED: June 6, 2014
16
17

ARIAS OZZELLO & GIGNAC LLP
J. PAUL GIGNAC
MISCHA N. BARTEAU
LAW OFFICE OF J.A. TED BAER
J.A. TED BAER

18
19

By:

/s/ J. Paul Gignac
J. PAUL GIGNAC
Attorneys for Plaintiff

20
21
22
DATED: June 6, 2014
23
24
25
26

MUNGER, TOLLES & OLSON LLP
KELLY M. KLAUS
JORDAN D. SEGALL
By:

/s/ Kelly M. Klaus
KELLY M. KLAUS
Attorneys for Defendants

27
28

2
STIP. AND [PROPOSED] ORDER TO MODIFY CASE
MGMT. CONF., HEARING & RELATED DATES
3:14-CV-01441-VC

1

In accordance with Local Rule 5-1(i), the filer attests that each of the above signatories

2 have concurred in the filing of this document.
3
4 DATED: June 6, 2014
5

By:

/s/ Kelly M. Klaus
KELLY M. KLAUS

6
7

PURSUANT TO STIPULATION, IT IS SO ORDERED.

8 Dated: June 9, 2014
9

By: __________________________________
HON. VINCE G. CHHABRIA
United States District Judge

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
STIP. AND [PROPOSED] ORDER TO MODIFY CASE
MGMT. CONF., HEARING & RELATED DATES
3:14-CV-01441-VC