Nunes v. Twitter, Inc.

Filing 54

AMENDED STIPULATION AND ORDER re 53 Order on Stipulation, Case stayed through 6/2/2015. Discovery due by 9/30/2015. Dispositive Motion Hearing set for 2/18/2016 10:00 AM in Courtroom 4, 17th Floor, San Francisco before Hon. Vince Chhabria. Signed by Judge Vince Chhabria on 3/5/2015. (knm, COURT STAFF) (Filed on 3/5/2015)

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JOHN G. JACOBS (PRO HAC VICE)
BRYAN G. KOLTON (PRO HAC VICE)
JACOBS KOLTON, CHTD.
55 West Monroe Street, Suite 2970
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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Attorneys for Plaintiff Beverly Nunes

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DAVID H. KRAMER, State Bar No. 168452
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant Twitter, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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BEVERLY NUNES, individually and on behalf
of a class of similarly situated individuals,
Plaintiff,

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v.

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TWITTER, INC.,

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Defendant.

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STIPULATION AND [PROPOSED]
ORDER REGARDING STAY AND SCHEDULE
CASE NO.: 14-CV-02843-VC

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CASE NO.: 14-cv-02843-VC
STIPULATION AND [PROPOSED]
ORDER STAYING PROCEEDINGS
AND MODIFYING CASE
SCHEDULE
AS MODIFIED

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On February 24, 2015, the parties in this matter participated in a mediation with the Hon.

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Read Ambler, and agreed to further discussions and a further mediation session that is currently

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scheduled to be conducted on March 24, 2015. In connection with their ongoing discussions, the

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parties have jointly agreed to request a three-month stay of proceedings in this matter, along with

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corresponding extensions to the existing case schedule. The parties’ agreement and request for a

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stay is made in good faith and not for purposes of delay.

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THE PARTIES THEREFORE STIPULATE through their undersigned counsel, subject
to the Court’s approval, that:

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1.

All proceedings in this matter should be stayed through June 2, 2015;

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2.

The existing case schedule should be modified as follows: Phase I Discovery

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completed by September 30, 2015; Initial Expert Witness statements shall be submitted

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by October 17, 2015; Rebuttal Expert Witness statements shall be submitted by Novem-

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ber 3, 2015; Motions for Summary Judgment on Phase 1 to be heard on February 19,

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2016 10:00 a.m.

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DATE: March 3, 2015

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David H. Kramer
WILSON SONSINI GOODRICH & ROSATI

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Attorney for Defendant Twitter, Inc.

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/s/ David H. Kramer

DATE: March 3, 2015

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/s/ John G. Jacobs
John G. Jacobs (PRO HAC VICE)
JACOBS KOLTON, CHTD
Jeffrey F. Keller
KELLER GROVER, LLP

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Attorneys for Plaintiff Beverly Nunes

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STIPULATION AND [PROPOSED]
ORDER REGARDING STAY AND SCHEDULE
CASE NO.: 14-CV-02843-VC

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PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING, IT IS HEREBY
ORDERED THAT:

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1.

All proceedings in this matter are stayed through June 2, 2015;

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2.

The existing case schedule is modified as follows: Phase I Discovery completed

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by September 30, 2015; Initial Expert Witness statements submitted by October

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17, 2015; Rebuttal Expert Witness statements submitted by November 3, 2015;
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Motions for Summary Judgment on Phase 1 to be heard on February 19, 2016

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10:00 a.m.

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5th
SIGNED this ____ day of March, 2015.

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__________________________________
VINCE CHHABRIA
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED]
ORDER REGARDING STAY AND SCHEDULE
CASE NO.: 14-CV-02843-VC

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