Hunter v. URS Corporation

Filing 52

ORDER, Reset Deadlines as to 43 MOTION to Transfer Case ; granting 51 STIPULATION WITH PROPOSED ORDER Regarding Briefing on Defendant's Motion to Transfer Venue filed by Michael Hunter. Responses due by 11/6/2015. Replies due by 11/20/2015. Signed by Judge Charles R. Breyer on 11/3/2015. (beS, COURT STAFF) (Filed on 11/4/2015)

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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]
Attorney for Plaintiff Michael Hunter and the Proposed Classes
Additional attorneys on signature page

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
MICHAEL HUNTER, individually and on
behalf of a class of similarly situated persons,

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Plaintiff,
v.
URS CORPORATION,
Defendant.

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Case No. 3:15-cv-2300 (CRB)
JOINT STIPULATION AND ORDER
REGARDING 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,

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2015, Defendant URS Corporation (“Defendant”) expressed its intent to file a Motion to Transfer

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this litigation (the “Motion”);

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WHEREAS, during the September 11, 2015 Case Management Conference, counsel for
Plaintiff Michael Hunter (“Plaintiff”) stated that Plaintiff will need certain discovery in order to
meaningfully respond to any motion to transfer; Complaint;
WHEREAS, the Court’s Order following the Case Management conference (Dkt. No. 42)
directed Defendant to file the Motion by September 25, 2015, and set a November 20, 2015 hearing
date, but did not set further discovery or briefing deadlines;
WHEREAS, on September 25, 2015, Defendant filed a Motion to Transfer Venue (Dkt. No.
43), including declarations by three witnesses;

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PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)

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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 to

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properly respond to the Motion, including deposition of the declarants supporting the Motion;
WHEREAS, Defendant provided objections and responses to Plaintiff’s discovery requests
and deposition notices on October 5, 2015;

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WHEREAS, and the Parties subsequently met and conferred regarding Defendant’s

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responses on October 22, 2015, and Defendant provided supplemental information thereafter, up to

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and including October 30, 2015;

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WHEREAS, the deadline for Plaintiff to oppose the Motion was set for October 9, 2015
pursuant to L.R. 7-3(a);
WHEREAS, the parties stipulated that Plaintiff’s Opposition to the Motion would be due

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October 30, 2015, with any Reply by Defendant due November 13, 2015;

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WHEREAS, Plaintiff’s Opposition to Defendant’s Motion is currently due October 30, 2015;

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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 November 6, 2015, with any Reply by Defendant due November

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20, 2015;

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WHEREAS, the hearing on the Motion is currently set for November 20, 2015;

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WHEREAS, the Parties propose that the hearing on the Motion be set for December 4, 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 Venue

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(Dkt. No. 43) is set for November 6, 2015, and Defendant’s deadline to file a Reply is November 20,

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2015.

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Respectfully submitted,

DATED: October 30, 2015

FRANCIS & MAILMAN, PC
/s/ James A. Francis
James A. Francis
John Soumilas

By:

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2

PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)

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Stephanie Tatar
Sarah R. Schalman-Bergen
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 30, 2015

SEYFARTH SHAW LLP
By:

/s/ Tamara Fisher
Laura J. Maechtlen
Pamela Q. Devata*
Tamara Fisher
William David

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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

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Attorneys for Defendant

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PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)

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ORDER
Upon consideration of the parties’ stipulation, it is hereby ordered that Plaintiff’s deadline to
file an Opposition to the Motion to Transfer Venue is November 6, 2015, and Defendant’s deadline
to file a Reply is November 20, 2015.

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IT IS SO ORDERED.

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Date: _Nov. 3, 2015_________________________

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______________________________
District Judge Charles R. Breyer

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PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO TRANSFER VENUE
CASE NO. 3:15-CV-2300 (CRB)