Pettit v. Procter & Gamble Company

Filing 29

STIPULATION AND ORDER RE 28 to extend Class Certification Briefing Schedule. Motion Hearing set for 11/10/2016 at 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 4/25/16. (cl, COURT STAFF) (Filed on 4/25/2016)

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GUTRIDE SAFIER LLP
ADAM J. GUTRIDE (State Bar No. 181446)
SETH A. SAFIER (State Bar No. 197427)
MARIE MCCRARY (State Bar No. 262670)
KRISTEN G. SIMPLICIO (State Bar No. 263291)
100 Pine Street, Suite 1250
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
TYCKO & ZAVAREEI LLP
LORENZO B. CELLINI
1828 L Street, N.W., Suite 1000
Washington, DC 20036
Telephone: [phone]
Facsimile: [phone]
SPANGENBERG SHIBLEY & LIBER LLP
STUART E. SCOTT
DANIEL FRECH
1001 Lakeside Avenue East, Suite 1700
Cleveland, OH 44114
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff, Jamie Pettit

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JAMIE PETTIT, an individual, on behalf of
herself, the general public and those similarly situated
Plaintiff,

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v.

CASE NO. 15-cv-2150-RS
ORDER
JOINT STIPULATION TO
EXTEND CLASS
CERTIFICATION
BRIEFING SCHEDULE

PROCTER & GAMBLE COMPANY
Defendant

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Pursuant to Civil L.R. 6-1(b), 6-2, and 7-12, plaintiff Jamie Pettit and defendant The
Procter & Gamble Company (“P&G”) respectfully submit this joint stipulation to extend the

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STIPULATION FOR CONTINUANCE OF
CLASS CERTIFICATION

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current briefing schedule for class certification.
WHEREAS, at the August 13, 2015 Case Management Conference and in a subsequent

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order, this Court set the hearing for Plaintiff’s Motion for Class Certification for May 5, 2016 and

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ordered that the Plaintiff shall file her opening brief on February 25, 2016, P&G shall file its

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opposition by March 28, 2016, and Plaintiff shall file her reply by April 14, 2016 [Dkt. No. 24];

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WHEREAS, the parties previously sought and received a time modification to permit the

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parties to review discovery taken to date and to defer additional discovery and briefing in light of

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the court’s order, in a similar case in which a plaintiff is challenging Charmin Freshmates

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flushable wipes (Belfiore v. Procter & Gamble Company, Case No. 14-cv-4090 (E.D.N.Y.)

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(Weinstein, J.)), that those parties participate in a settlement talks with Magistrate Judge Levy,

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which began on January 21;

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WHEREAS, the parties agreed and on February 11, 2016, this Court so ordered that

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Plaintiff shall file her motion for class certification by May 19, 2016; P&G shall file its

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opposition by June 23, 2016; Plaintiff shall file her reply by July 14, 2016; and the hearing shall

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be held at 1:30 p.m. on August 4, 2016 [Dkt. # 27];

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WHEREAS, the settlement discussions being conducted under Magistrate Judge Levy’s
direction are continuing;
WHEREAS, the parties are deferring depositions and other discovery matters so as to
conserve resources while those settlement discussions continue;

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WHEREAS, there has been one previous time modification in this case, discussed above;

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WHEREAS, in light of the foregoing, Plaintiff and P&G request that the briefing schedule

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for Plaintiff’s motion for class certification be continued approximately three months;
WHEREAS, the effect of the requested time modification will to be extend the current
class certification briefing schedule approximately three months; and

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WHEREAS, the parties have agreed that Plaintiff shall file her motion for class

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certification by August 24, 2016; P&G shall file its opposition by September 28, 2016; Plaintiff

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shall file her reply by October 19, 2016; and the hearing shall be held at 1:30 p.m. on November

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10, 2016, or another date convenient for the Court;
STIPULATION FOR CONTINUANCE OF
CLASS CERTIFICATION

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NOW THEREFORE, THE PARTIES BY COUNSEL HEREBY STIPULATE:

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Plaintiff shall file her motion for class certification by August 24, 2016; P&G shall file its

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opposition by September 28, 2016; Plaintiff shall file her reply by October 19, 2016; and the

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hearing shall be held at 1:30 p.m. on November 10, 2016 or another date convenient for the

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Court.

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Dated:

April 25, 2016
GUTRIDE SAFIER LLP

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By: /s/ Kristen G. Simplicio
Kristen G. Simplicio

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Attorneys for Plaintiff
Jamie Pettit

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DATED: April 25, 2016

COVINGTON & BURLING LLP
By:/s/ Cortlin Lannin
Cortlin Lannin

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Attorneys for Defendant
The Procter & Gamble Company

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: 4/25/16

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THE HONORABLE RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE

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STIPULATION FOR CONTINUANCE OF
CLASS CERTIFICATION

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