Rulli et al v. Nielsen Company (U.S.) LLC

Filing 34

ORDER DENYING REQUEST TO CONTINUE THE CASE MANAGEMENT CONFERENCE. Signed by Judge Vince Chhabria on 10/3/2014. (knm, COURT STAFF) (Filed on 10/3/2014)

Case 3-14-cv-01835-VC

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Document 33

Filed in CAND on 09/30/2014

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David Borgen (SBN 099354)
[e-mail]
James Kan (SBN 240749)
[e-mail]
GOLDSTEIN, BORGEN, DARDARIAN & HO
300 Lakeside Drive, Suite 1000
Oakland, CA 94612
Tel: [phone]
Fax: [phone]
Gregg I. Shavitz
[e-mail]
SHAVITZ LAW GROUP, P.A.
1515 South Federal Highway Suite 404
Boca Raton, FL 33432
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiffs and the Putative Class

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Lynne C. Hermle (SBN 99779)
Jessica R. Perry (SBN 209321)
Julia Collins Riechert (SBN 254078)
ORRICK, HERRINGTON & SUTCLIFFE LLP
1000 Marsh Road
Menlo Park, California 94025
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant
NIELSEN COMPANY (U.S.) LLC

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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STEVE RULLI, JOSE BUENROSTRO,
EDWIN BUMP, and ENRIQUE CRUZ on
behalf of themselves and all others similarly
situated,

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Plaintiffs,

Case No.: 3:14-CV-01835 VC
CLASS, COLLECTIVE, AND
REPRESENTATIVE ACTION
SECOND JOINT CASE MANAGEMENT
STATEMENT

vs.
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NIELSEN COMPANY (U.S.) LLC,

AND ORDER DENYING REQUEST TO CONTINUE

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Defendant.
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549571.3

SECOND JOINT CASE MANAGEMENT STATEMENT– CASE NO. 3:14-CV-01835 VC

Case 3-14-cv-01835-VC

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Document 33

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JOINT CASE MANAGEMENT STATEMENT
The parties, by and through their counsel, jointly submit this Second Joint Case Management

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Statement in anticipation of the Case Management Conference scheduled for October 7, 2014, at

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10:00 a.m.

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I.

SETTLEMENT REACHED AND SCHEDULING ISSUES

On September 16, 2014, the parties attended a mediation session with experienced mediator

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Mark Rudy. After the full day of negotiations, the parties reached a settlement in principle and

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executed a memorandum of understanding to that effect. The parties are currently working together to

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complete and execute a comprehensive settlement agreement. They will use their best efforts to

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finalize the settlement agreement no later than October 20, 2014 and to file promptly thereafter a

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motion for preliminary approval.

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Because the mediation was successful, the parties request that the Court vacate any further
litigation deadlines.

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II.

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Plaintiffs have retained Gregg Shavitz of the Shavitz Law Group, P.A. to co-counsel with

DISCLOSURE OF NON-PARTY INTERESTED ENTITIES OR PERSONS

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Goldstein, Borgen Dardarian & Ho. They hereby disclose the Shavitz Law Group, P.A. as a non-party

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interested entity or person.

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III.

OTHER MATTERS

The parties respectfully request that the Court vacate the Case Management Conference set for

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October 7, 2014 so that they may focus their efforts on finalizing a settlement agreement. They also

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respectfully request that the Court set a further case management conference for November 18, 2014 at

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10:00 a.m. or shortly thereafter when the Court is available so that the parties may report about their

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progress.

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Dated: September 30, 2014

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Respectfully submitted,
GOLDSTEIN, BORGEN, DARDARIAN & HO

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/s/ James Kan
James Kan

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Attorneys for Plaintiffs and the Putative Class
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549571.3

SECOND JOINT CASE MANAGEMENT STATEMENT– CASE NO. 3:14-CV-01835 VC

Case 3-14-cv-01835-VC

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Document 33

Dated: September 30, 2014

Filed in CAND on 09/30/2014

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ORRICK, HERRINGTON & SUTCLIFFE LLP

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/s/ Julia Collins Riechert
Julia Collins Riechert

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Attorneys for Defendant

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ATTESTATION
Pursuant to General Order 45(X), I attest that concurrence in the filing of this document has
been obtained from each of the other signatories.

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GOLDSTEIN, BORGEN, DARDARIAN & HO

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September 30, 2014

By: /s/ James Kan
James Kan

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Attorneys for Plaintiffs

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Jud

ER

H

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RT

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R NIA

e Chha
g e Vi n c

case management conference is

br ia

LI

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D
DENIE

The parties' request to continue the

denied. The parties must appear in
person on Tuesday, October 7, 2014,
at 10:00 a.m.

A

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UNIT
ED

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Date: October 3, 2014

NO

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RT
U
O

S

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S DISTRICT
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TA

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D IS T IC T
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549571.3

SECOND JOINT CASE MANAGEMENT STATEMENT– CASE NO. 3:14-CV-01835 VC