Rosen .v Uber Technologies, Inc.

Filing 86

STIPULATION AND ORDER re 85 STIPULATION WITH PROPOSED ORDER re 82 MOTION to Withdraw as Attorney filed by Rasier, LLC, Uber Technologies, Inc., Rasier-CA, LLC. Further Case Management Conference set for 3/9/2017 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on March 2, 2017. (wsn, COURT STAFF) (Filed on 3/2/2017)

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.
11 MARTIN D. WHITE (BAR NO. 253476)
1455 Market Street, 4th Floor
12 San Francisco, CA 94103
Phone: [phone]
13 E-Mail: [e-mail]
14 Attorneys for Defendants

UBER TECHNOLOGIES, INC.; RASIER, LLC;

15 RASIER-CA, LLC
16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA

18
19 STEWART ROSEN, on Behalf of Himself
and All Others Similarly Situated, and as
20 Private Attorney General,
Plaintiffs,

21
22

vs.

23 UBER TECHNOLOGIES, INC., a
Delaware corporation; RASIER, LLC, a
24 Delaware limited liability company;
RASIER-CA, LLC, a Delaware limited
25 liability company; and DOES 1 to 100,
inclusive,
26
Defendants.
27

Case No. 15-cv-03866-JST
ASSIGNED FOR ALL PURPOSES TO
Judge Jon S. Tigar
STIPULATION FOR ORDER
SHORTENING TIME FOR HEARING
ON PLAINTIFF'S COUNSEL'S
MOTION TO WITHDRAW AND
SETTING CASE MANAGEMENT
CONFERENCE

28
LAW OFFICES

Allen Matkins Leck Gamble
Mallory & Natsis LLP

1071442.01/LA

Stipulation For Order Shortening Time For Hearing On
Motion To Withdraw And Setting Case Management
Conference

1

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

2 follows:
3

1.

On February 8, 2016, the Court entered the Consolidated Joint Case

4 Management Schedule, setting certain dates in this matter including, but not limited to, a
5 briefing schedule and an April 13, 2017 hearing date for Plaintiff's Motion for Class
6 Certification. (Docket No. 34.)
7

2.

On February 17, 2017, Plaintiff's counsel filed a Motion to Withdraw as

8 Counsel (Docket No. 82) and set the hearing date on such motion for April 13, 2017, the
9 same date as the hearing on Plaintiff's Motion for Class Certification (Docket No. 67).
10

3.

On February 27 and 28, 2017, Plaintiff's counsel and Defendants' counsel

11 met and conferred and agreed that, to avoid incurring potentially unnecessary fees and
12 costs, Plaintiff's counsel's Motion to Withdraw should be heard prior to the filing of
13 Defendants' Opposition to the Motion for Class Certification, and that the Court and
14 parties would benefit from a case management conference to discuss any scheduling issues
15 and other issues, including the continuance of dates regarding the Motion for Class
16 Certification and any dispositive motions, that may arise from the Court's ruling on the
17 Motion to Withdraw. Plaintiff further understands and agrees that, based on Defendants'
18 reliance on this stipulation and to avoid incurring legal expense that may be unnecessary,
19 Defendants have suspended work on their Opposition to the Motion for Class Certification,
20 pending the Court's ruling on the Motion to Withdraw and resetting of the briefing
21 schedule for the Motion for Class Certification.
22

4.

Therefore, the parties agree that the hearing date on Plaintiff's Motion to

23 Withdraw should be advanced to March 9, 2017, and that the Court should set a Case
24 Management Conference for the same date to discuss the resetting of the remaining dates
25 on calendar, including but not limited to the briefing schedule and hearing date on
26 Plaintiff's Motion for Class Certification and any dispositive motions.
27
28
LAW OFFICES

Allen Matkins Leck Gamble
Mallory & Natsis LLP

1071442.01/LA

-2-

Stipulation For Order Shortening Time For Hearing On
Motion To Withdraw And Setting Case Management
Conference

5.

1

By entering into this stipulation, the parties reserve, and do not waive, any

2 and all rights, claims, defenses and arguments they may have on the aforementioned
3 motions specifically and in this action generally.
4
5 Dated: March 1, 2017
6

LAW OFFICES OF HAROLD M. JAFFE
By:

7
8
9
10

Dated: March 1, 2017

/s/ Harold M. Jaffe
HAROLD M. JAFFE
Attorneys for Plaintiff
STEWART ROSEN

ALLEN MATKINS LECK GAMBLE
MALLORY & NATSIS LLP

11
By:

12
13
14

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

15
16 IT IS SO ORDERED.
17
18 Dated:

__________________________________
HONORABLE JON S. TIGAR
UNITED STATES DISTRICT COURT

19
20
21
March 2, 2017
22 ________________________

23
24
25
26
27
28
LAW OFFICES

Allen Matkins Leck Gamble
Mallory & Natsis LLP

1071442.01/LA

-3-

Stipulation For Order Shortening Time For Hearing On
Motion To Withdraw And Setting Case Management
Conference