Robinson v. The Chefs' Warehouse

Filing 71

STIPULATION AND ORDER RE 70 to Extend Expert Deadlines. Signed by Judge Richard Seeborg on 3/3/17. (cl, COURT STAFF) (Filed on 3/3/2017)

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HOFFMAN EMPLOYMENT LAWYERS
MICHAEL HOFFMAN (SBN 154481)
[e-mail]
LEONARD EMMA (SBN 224483)
[e-mail]
STEPHEN NOEL ILG (SBN 275599)
[e-mail]
580 California Street, Suite 1600
San Francisco, CA 94104
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff SHAON ROBINSON

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA

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SHAON ROBINSON, SEAN CLARK, on
behalf of themselves, all others similarly
situated, and the general public,

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Case No. 15-cv-05421
ORDER
JOINT STIPULATION TO EXTEND
EXPERT DEADLINES

Plaintiff,
vs.
THE CHEFS’ WAREHOUSE, INC., a
Delaware corporation, THE CHEFS’
WAREHOUSE WEST COAST, LLC, a
California limited liability company, and
DOES 1 through 100, inclusive,
Defendants.

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-1Shaon Robinson v. The Chefs’ Warehouse, Inc.
Stipulation to Continue Expert Deadlines

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Plaintiffs SHAON ROBINSON and SEAN CLARK, on behalf of themselves and all

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others similarly situated, (“Plaintiffs”) and THE CHEFS’ WAREHOUSE, INC. and THE

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CHEFS’ WAREHOUSE WEST COAST, LLC (“Defendants”) (collectively, the “Parties”), by

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and through their respective counsel of record, hereby stipulate and agree as follows:

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WHEREAS, on March 24, 2016, the Court entered a Case Management Scheduling
Order (Dkt. 20) (the “Order”).

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WHEREAS, the Order set forth the following deadlines:

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

Federal Rule of Civil Procedure 26(a)(2).

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



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On or before April 28, 2017, all discovery of expert witnesses pursuant to
Federal Rule of Civil Procedure 26(b)(4) shall be completed.

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On or before March 17, 2017, parties will designate their supplemental and
rebuttal experts in accordance with Federal Rule of Civil Procedure 26(a)(2).

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On or before March 3, 2017, parties will designate experts in accordance with

WHEREAS, based on the current Order, Plaintiffs’ motion for class certification shall be
heard on September 21, 2017.
WHEREAS, the Parties are engaged in fact discovery disputes and mutually agree it

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would be beneficial and a conservation of time and resources to conduct further fact discovery,

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resolve outstanding fact discovery disputes that may impact the production of contact

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information and documents (including time records and wage statements) for putative class

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members, and obtain a ruling on class certification before exchanging expert-related disclosures.

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WHEREAS, this is the Parties’ first stipulation to extend expert discovery deadlines.

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NOW, THEREFORE, IT IS HEREBY STIPULATED between the Parties, by and

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through their respective attorneys of record, subject to an order of the Court, that expert-related

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deadlines be continued as set forth below:

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

October 23, 2017, parties will designate experts in accordance with Federal
Rule of Civil Procedure 26(a)(2).

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-2Shaon Robinson v. The Chefs’ Warehouse, Inc.
Stipulation to Continue Expert Deadlines

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

experts in accordance with Federal Rule of Civil Procedure 26(a)(2).

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November 6, 2017, parties will designate their supplemental and rebuttal

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December 18, 2017, all discovery of expert witnesses pursuant to Federal
Rule of Civil Procedure 26(b)(4) shall be completed.

IT IS SO STIPULATED.

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Respectfully submitted,

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Dated: March 2, 2017

HOFFMAN EMPLOYMENT LAWYERS

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/s/ Stephen Noel Ilg
______________________________________
Stephen Noel Ilg
Attorneys for SHAON ROBINSON and SEAN
CLARK on behalf of themselves, all others
similarly situated, and the general public

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Dated: March 2, 2017

REED SMITH LLP
/s/ Julia Y. Trankiem
______________________________________
Julia Y. Trankiem
Attorneys for THE CHEFS’ WAREHOUSE
WEST COAST, LLC, erroneously sued as THE
CHEFS’ WAREHOUSE, INC.

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Attestation
Pursuant to Northern District L.R. 5-1(i)(3) regarding signatures, I hereby attest that

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concurrence in the filing of this document has been obtained from each of the other signatories.
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I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.

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-3Shaon Robinson v. The Chefs’ Warehouse, Inc.
Stipulation to Continue Expert Deadlines

/s/ Stephen Noel Ilg________________
STEPHEN NOEL ILG
HOFFMAN EMPLOYMENT LAWYERS
Attorneys for Plaintiffs

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated:_____________________
3/3/17

__________________________________________

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RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE

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-4Shaon Robinson v. The Chefs’ Warehouse, Inc.
Stipulation to Continue Expert Deadlines