Rosen .v Uber Technologies, Inc.

Filing 81

STIPULATION AND ORDER re 77 STIPULATION WITH PROPOSED ORDER Extending Deadline for Defendant Class Expert Designation and Report filed by Rasier, LLC, Uber Technologies, Inc., Rasier-CA, LLC. Signed by Judge Jon S. Tigar on February 16, 2017. (wsn, COURT STAFF) (Filed on 2/16/2017)

1 ALLEN MATKINS LECK GAMBLE

MALLORY & NATSIS LLP

2 MARSHALL C. WALLACE (BAR NO. 127103)

KAMRAN JAVANDEL (BAR NO. 272900)

3 Three Embarcadero Center, 12th Floor

San Francisco, CA 94111-4074

4 Phone: [phone]

Fax: [phone]

5 E-Mail: [e-mail]
6

[e-mail]

MARISSA M. DENNIS (BAR NO. 245027)

7 865 South Figueroa Street, Suite 2800

Los Angeles, California 90017-2543

8 Phone: [phone]

Fax: [phone]

9 E-Mail: [e-mail]
10 UBER TECHNOLOGIES, INC.
MARTIN D. WHITE (BAR NO. 253476)
11 1455 Market Street, 4th Floor
San Francisco, CA 94103
12 Phone: [phone]
E-Mail: [e-mail]
13

Attorneys for Defendants

14 UBER TECHNOLOGIES, INC.; RASIER, LLC;
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RASIER-CA, LLC

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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STEWART ROSEN, on Behalf of Himself
19 and All Others Similarly Situated, and as
Private Attorney General,
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Plaintiffs,
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vs.
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UBER TECHNOLOGIES, INC., a
23 Delaware corporation; RASIER, LLC, a
Delaware limited liability company;
24 RASIER-CA, LLC, a Delaware limited
liability company; and DOES 1 to 100,
25 inclusive,

Case No. 15-cv-03866-JST
ASSIGNED FOR ALL PURPOSES TO
Judge Jon S. Tigar
STIPULATION FOR ORDER
EXTENDING DEADLINE FOR
DEFENDANT CLASS EXPERT
DESIGNATION AND REPORT

Defendants.

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LAW OFFICES

Allen Matkins Leck Gamble
Mallory & Natsis LLP

1070395.02/LA

STIPULATION FOR ORDER EXTENDING
DEADLINE FOR DEFENDANT CLASS
EXPERT DESIGNATION AND REPORT

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The parties to this action, by and through their attorneys of record, stipulate as

2 follows:
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1.

On November 14, 2016, the Court signed the parties' Stipulation for Order

4 Regarding Limited Modifications to Scheduling Order in Rosen Action. In such
5 stipulation, the parties agreed that Defendants' class certification expert designations and
6 report would be served on February 17, 2017. (Docket No. 52.)
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2.

On February 14, 2017, Plaintiff's counsel sent written notice to Defendants'

8 counsel that they would be filing a Notice of Motion and Motion to Withdraw as Counsel
9 ("Motion to Withdraw") in this action, and also that they were withdrawing one of
10 Plaintiff's designated expert witnesses, S. Ronald Hauri, as an expert witness in this matter.
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3.

On February 15, 2017, Plaintiff's counsel and Defendants' counsel met and

12 conferred by telephone and agreed that, in order to avoid incurring potentially unnecessary
13 fees and costs, the deadline for Defendants' class expert designations and report should be
14 extended from February 17, 2017 to seven (7) days after any written demand for such
15 designation and report by Plaintiff or Plaintiff's then-current counsel of record.
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4.

The parties note that the requested extension affects only the parties'

17 deadlines, and does not affect the timing or contents of any of the documents to be
18 submitted to the Court or hearings to be conducted by the Court.
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20 Dated: February 15, 2017
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LAW OFFICES OF BRIAN W. NEWCOMB
By:

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/s/ Brian W. Newcomb
BRIAN W. NEWCOMB
Attorneys for Plaintiff
STEWART ROSEN

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LAW OFFICES

Allen Matkins Leck Gamble
Mallory & Natsis LLP

1070395.02/LA

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STIPULATION FOR ORDER EXTENDING
DEADLINE FOR DEFENDANT CLASS
EXPERT DESIGNATION AND REPORT IN
ROSEN ACTION

1 Dated: February 15, 2017
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3

ALLEN MATKINS LECK GAMBLE
MALLORY & NATSIS LLP
By:

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/s/ Marissa M. Dennis
MARISSA M. DENNIS
Attorneys for Defendants
UBER TECHNOLOGIES, INC.;
RASIER, LLC; RASIER-CA, LLC

IT IS SO ORDERED.

Dated:

__________________________________
HONORABLE JON S. TIGAR
UNITED STATES DISTRICT COURT

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February 16, 2017
________________________

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LAW OFFICES

Allen Matkins Leck Gamble
Mallory & Natsis LLP

1070395.02/LA

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STIPULATION FOR ORDER EXTENDING
DEADLINE FOR DEFENDANT CLASS
EXPERT DESIGNATION AND REPORT IN
ROSEN ACTION

ECF ATTESTATION FOR MULTIPLE SIGNATURES

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I, Marissa M. Dennis, the ECF user whose ID and password were utilized in the

3 electronic filing of this document, hereby attests that concurrence in the filing of this
4 document has been obtained from each of the other signatories, which shall serve in lieu of
5 their signatures on the document.
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/s/ Marissa M. Dennis

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Marissa M. Dennis

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LAW OFFICES

Allen Matkins Leck Gamble
Mallory & Natsis LLP

1070395.02/LA

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STIPULATION FOR ORDER EXTENDING
DEADLINE FOR DEFENDANT CLASS
EXPERT DESIGNATION AND REPORT IN
ROSEN ACTION