Reardon et al v. Uber Technologies, Inc.

Filing 40

STIPULATION AND ORDER re 38 STIPULATION WITH PROPOSED ORDER to Continue Case Management Conference filed by Jennifer Reilly, Justin Bartolet, Jonathan Grindell, Sandeep Pal, James Lathrop, Kerry Reardon, Julie McKinney. Initial Case Management Conference set for 5/20/2015 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on April 29, 2015. (wsn, COURT STAFF) (Filed on 4/29/2015)

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1 2 3 4 5 6 7 8 9 10 11 12 Hassan A. Zavareei (SBN 181547) hzavareei@tzlegal.com TYCKO & ZAVAREEI LLP 2000 L Street, N.W., Suite 808 Washington, DC 20036 Tel.: (202) 973-0900 Fax: (202) 973-0950 Attorney for Plaintiffs Kerry Reardon, James Lathrop, Julie McKinney, Jonathan Grindell, Sandeep Pal, Jennifer Reilly, and Justin Bartolet LOCKE LORD LLP Susan J. Welde (SBN: 205401) swelde@lockelord.com 300 South Grand Avenue, Suite 2600 Los Angeles, California 90071 Telephone: (213) 485-1500 Facsimile: (213) 485-1200 16 LOCKE LORD LLP Martin Jaszczuk (Pro Hac Vice) mjaszczuk@lockelord.com Nick J. Di Giovanni (Pro Hac Vice) ndigiovanni@lockelord.com 111 S. Wacker Drive Chicago, Illinois 60606 Telephone: (312) 443-0700 Facsimile: (312) 443-0336 17 Attorneys for Defendant Uber Technologies, Inc. 13 14 15 18 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 19 20 21 22 23 24 25 26 PLAINTIFFS KERRY REARDON, JAMES LATHROP, JULIE MCKINNEY, JONATHAN GRINDELL, SANDEEP PAL, JENNIFER REILLY, and JUSTIN BARTOLET on behalf of themselves and all others similarly situated, Civil Action No. 14-cv-05678-JST Honorable Jon S. Tigar STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Plaintiffs, v. UBER TECHNOLOGIES, INC. 27 28 Defendant. -1STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Civil Action No. 14-cv-05678-JST 1 Plaintiffs KERRY REARDON, JAMES LATHROP, JULIE MCKINNEY, JONATHAN 2 GRINDELL, SANDEEP PAL, JENNIFER REILLY, and JUSTIN BARTOLET and Defendant 3 UBER TECHNOLOGIES, INC. (collectively, “the Parties”) hereby submit, through the 4 undersigned counsel of record, the following Stipulation to Continue the Case Management 5 Conference currently scheduled in this matter. In support of this stipulation, the Parties state as 6 follows: 7 8 1. Plaintiffs filed their initial Complaint on December 31, 2014. The case was initially assigned to Judge Joseph Spero. 9 2. On January 7, 2015, the Court entered an Order Setting Initial Case Management 10 Conference and ADR Deadlines. That Order set the Case Management Conference for April 3, 11 2015. 12 13 3. Defendant’s response. 14 15 16 17 18 19 20 Plaintiffs filed their First Amended Complaint on January 30, 2015, prior to 4. On February 18, 2015, the case was reassigned to the Honorable John S. Tigar by the 5. On February 19, 2015, the Court set a new date for the Initial Case Management Court. Conference before Judge Tigar of April 22, 2015. 6. Defendant filed its partial Motion to Dismiss the First Amended Complaint on February 27, 2015. That Motion is now fully briefed. 7. On March 31, 2015, the Court continued the Initial Case Management Conference to 21 May 13, 2015. The Court also reset the deadline for the filing of the Joint Case Management 22 Statement to April 29, 2015. 23 24 25 8. The Parties have been meeting and conferring regarding the Joint Case Management Statement and timely filed that document on today’s date. See Docket No. 37. 9. However, counsel for Plaintiffs is unavailable to personally attend the Initial Case 26 Management Conference now scheduled for May 13, 2015 because it is his daughter’s birthday. 27 Counsel for Plaintiffs lives in Washington, DC and is unable to travel to San Francisco on May 13, 28 2015 due to personal family commitments related to his daughter’s birthday. -2STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Civil Action No. 14-cv-05678-JST 1 10. The Parties have communicated with Judge Tigar’s Courtroom Deputy and 2 understand that the Court may be available to reschedule the Initial Case Management Conference 3 for the following Wednesday, May 20, 2015 4 5 6 7 8 IT IS THEREFORE STIPULATED AND AGREED by the Parties, through the undersigned, as follows: 1. The Parties agree to continue the Initial Case Management Conference to May 20, 2015 at 2:00 pm, or another date and time agreeable to the Court. IT IS SO STIPULATED. 9 10 DATED: April 29, 2015 TYCKO AND ZAVAREEI, LLP 11 12 By /s/ Hassan A. Zavareei 13 Hassan A. Zavareei 14 Attorney for Plaintiffs 15 16 17 DATED: April 29, 2015 LOCKE LORD LLP 18 19 By 20 /s/ Martin Jaszczuk Attorney for Defendant 21 S 24 DATED: ______________ April 29, 2015 R NIA DERED SO OR IT IS __________________________________ The Honorable Jon S. Tigar UNITED STATES DISTRICT JUDGE RT -3- ER . Ti ga r H 28 nS J u d ge J o FO NO 27 LI 26 A 25 RT U O 23 S DISTRICT TE C TA PURSUANT TO STIPULATION, IT IS SO ORDERED. UNIT ED 22 N STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCEO D IS T IC T R Civil Action No. 14-cv-05678-JST F C 1 2 3 FILER’S ATTESTATION Pursuant to General Order No. 45, Section X, Subparagraph B, the undersigned attests that all parties have concurred in the filing of this Stipulation. 4 5 6 DATED: April 29, 2015 TYCKO AND ZAVAREEI LLP By /s/ Hassan A. Zavareei Hassan A. Zavareei 7 Attorney for Plaintiffs 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Civil Action No. 14-cv-05678-JST

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