Hunter v. URS Corporation

Filing 50

ORDER granting 48 STIPULATION WITH PROPOSED ORDER re 43 MOTION to Transfer Case filed by Michael Hunter. Reset Deadlines as to 43 MOTION to Transfer Case . Responses due by 10/30/2015. Replies due by 11/13/2015. Signed by Judge Charles R. Breyer on 10/20/2015. (beS, COURT STAFF) (Filed on 10/21/2015)

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TATAR LAW FIRM, APC
Stephanie R. Tatar (CA Bar No. 237792)
[e-mail]
3500 West Olive Avenue, Suite 300
Burbank, CA 91505
Telephone: [phone] / Facsimile: [phone]

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Attorney for Plaintiff Michael Hunter and the Proposed Classes
Additional attorneys on signature page
SEYFARTH SHAW LLP
Laura J. Maechtlen (CA Bar No. 224923)
[e-mail]
Tamara Fisher (CA Bar No. 238170)
[e-mail]
William David (CA Bar No. 302016)
[e-mail]
560 Mission Street, 31st Floor
San Francisco, California 94105
Telephone: [phone] / Facsimile: [phone]

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Attorneys for Defendant URS Corporation
Additional attorney on signature page

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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MICHAEL HUNTER, individually and on
behalf of a class of similarly situated persons,
Plaintiff,

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v.
URS CORPORATION,
Defendant.

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Case No. 3:15-cv-2300 (CRB)
STIPULATION AND ORDER
REGARDING DISCOVERY AND
BRIEFING ON DEFENDANT’S
MOTION TO TRANSFER VENUE
Judge: Hon. Charles R. Breyer

WHEREAS, during the Case Management Conference held by the Court on September 11,
2015, Defendant URS Corporation (“Defendant”) expressed its intent to file a Motion to Transfer
this litigation (the “Motion”);

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND
BRIEFING ON DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)

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WHEREAS, during the September 11, 2015 Case Management Conference, counsel for

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Plaintiff Michael Hunter (“Plaintiff”) stated that Plaintiff will need certain discovery in order to

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meaningfully respond to any motion to transfer;

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WHEREAS, the Court’s Order following the Case Management conference (Dkt. No. 42)

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directed Defendant to file the Motion by September 25, 2015, and set a November 20, 2015 hearing

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date, but did not set further discovery or briefing deadlines;

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WHEREAS, on September 25, 2015, Defendant filed a Motion to Transfer (Dkt. No. 43),
including declarations by three witnesses;

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WHEREAS, on September 29, 2015, Plaintiff served written discovery requests and

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deposition notices seeking information, documents, and testimony which he contends is necessary

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to properly respond to the Motion, including deposition of the declarants supporting the Motion;

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WHEREAS, the current deadline for Plaintiff to oppose the Motion is set for October 9,
2015 pursuant to L.R. 7-3(a);

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WHEREAS, the Parties have met and conferred and jointly propose that Plaintiff’s

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Opposition to the Motion be due October 30, 2015, with any Reply by Defendant due November

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13, 2015;

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WHEREAS, the proposed briefing schedule will not affect the hearing on the Motion
currently set for November 20, 2015.

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IT IS HEREBY STIPULATED by and between the parties, through their respective counsel

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of record, that Plaintiff’s deadline to file an Opposition to Defendant’s Motion to Transfer (Dkt. No.

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43) is set for October 30, 2015, and Defendant’s deadline to file a Reply is set for November 13,

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2015.

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Respectfully submitted,

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DATED: October 5, 2015
By:

FRANCIS & MAILMAN, PC
/s/ James A. Francis
James A. Francis
John Soumilas
Stephanie Tatar
Sarah R. Schalman-Bergen
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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND
BRIEFING ON DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)

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Shanon J. Carson

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FRANCIS & MAILMAN, P.C.
James A. Francis, (PA Bar No. 77474)*
[e-mail]
John Soumilas (PA Bar No. 84527)*

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[e-mail]
100 S. Broad Street, 19th Floor
Philadelphia, PA 19110
Telephone: [phone]
Facsimile: [phone]

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BERGER & MONTAGUE, P.C.
Sarah R. Schalman-Bergen (PA Bar No. 206211)*
[e-mail]
Shanon J. Carson (PA Bar No. 85957)*
[e-mail]
1622 Locust Street
Philadelphia, PA 19103
Telephone: [phone]
Facsimile: [phone]
*admitted pro hac vice

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Attorneys for Plaintiff Michael Hunter and the
Proposed Classes

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DATED: October 5, 105

SEYFARTH SHAW LLP
By:

/s/ Tamara Fisher
Laura J. Maechtlen
Pamela Q. Devata*
Tamara Fisher
William David
SEYFARTH SHAW LLP
Pamela Q. Devata (IL Bar No. 6275731)*
[e-mail]
131 South Dearborn Street, Suite 2400
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
*admitted pro hac vice
Attorneys for Defendant

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND
BRIEFING ON DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)

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ORDER

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Upon consideration of the parties’ stipulation to set a briefing schedule on Defendant’s

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Motion to Transfer, it is hereby ordered that Plaintiff’s deadline to file an Opposition to the Motion

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to Transfer Venue is October 30, 2015, and Defendant’s deadline to file a Reply is November 13,

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2015.

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IT IS SO ORDERED.

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Date: October 20, 2015
District Judge Charles R. Breyer

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND
BRIEFING ON DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)