Castillo et al v. Seagate Technology, LLC

Filing 28

STIPULATION AND ORDER RE 27 Continuing July 21, 2016 Case Management Conference. Case Management Statement due by 9/1/2016. Initial Case Management Conference previously set for 7/21/2016 Continued to 9/8/2016 at 10:00 AM in Courtroom 3, 17th Floor, San Francisco.Signed by Judge Richard Seeborg on 7/5/16. (cl, COURT STAFF) (Filed on 7/6/2016)

1
2
3
4
5
6
7
8
9
10

DAVID F. MCDOWELL (CA SBN 125806)
[e-mail]
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, California 90017-3543
Telephone: [phone]
Facsimile: 213.892.5454
TIFFANY CHEUNG (CA SBN 211497)
[e-mail]
ALEXANDRA E. LAKS (CA SBN 291861)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Defendant
SEAGATE TECHNOLOGY LLC

11
12

UNITED STATES DISTRICT COURT

13

NORTHERN DISTRICT OF CALIFORNIA

14

SAN FRANCISCO DIVISION

15
16
17
18

EVERETT CASTILLO, LINDA CASTILLO,
NICHOLAS DATTOMA, FREDA LANG,
WENDY TRAN, and STEVEN WILK,
individually and on behalf of all others similarly
situated,

21
22

3:16-cv-01958-RS

STIPULATION AND [PROPOSED]
ORDER CONTINUING JULY 21,
2016 CASE MANAGEMENT
CONFERENCE

Plaintiffs,

19
20

Case No.

v.

Judge:
Action Filed:

Hon. Richard Seeborg
April 14, 2016

SEAGATE TECHNOLOGY LLC,
Defendant.

23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-CV-01958-RS
sf-3668390

1

Pursuant to Local Rules 6-2 and 7-12, Plaintiffs EVERETT CASTILLO, LINDA

2

CASTILLO, NICHOLAS DATTOMA, FREDA LANG, WENDY TRAN, and, STEVEN

3

WILK (“Plaintiffs”), on behalf of themselves and all others similarly situated, and Defendant

4

Seagate Technology LLC (“Seagate”), through their undersigned counsel, hereby stipulate as

5

follows:

6

WHEREAS, on June 15, 2016, the Court granted the parties’ stipulation to consolidate

7

two actions related to Seagate’s security practices: Castillo et al. v. Seagate Technology LLC,

8

No. 3:16-cv-01958-RS (filed on April 14, 2016) and Dattoma v. Seagate Technology LLC, No.

9

C5:16-cv-02136-RS (filed on April 21, 2016) (Dkt. No. 19);

10
11
12
13

WHEREAS, Plaintiffs filed their Amended Consolidated Complaint on June 28, 2016
(Dkt. No. 22);
WHEREAS, pursuant to the parties’ stipulation and the Court’s Order, Seagate’s
deadline to file its response is July 28, 2016 (See Dkt. No. 19 1:26-2:2);

14

WHEREAS, the Case Management Conference for this matter is currently scheduled for

15

July 21, 2016, and the Joint Case Management Statement is due a week earlier, on July 14, 2016

16

(See Castillo Dkt. No. 9; Dattoma Dkt. No. 12);

17

WHEREAS, the parties agree that judicial efficiency would best be served by continuing

18

the Case Management Conference until after Seagate has had the opportunity to analyze the

19

allegations in the Amended Consolidated Complaint and to allow the parties an opportunity to

20

meaningfully confer about the claims and defenses at issue and to brief any pleading motion;

21

WHEREAS, the parties agree that the Case Management Conference should be

22

rescheduled to September 8, 2016 or a date thereafter convenient for the Court;

23

WHEREAS, the parties agree that all dates based on the initial case management

24

conference, including the parties’ deadline to meet and confer regarding initial disclosures, early

25

settlement, the ADR process, and a discovery plan, as well as their deadline to file the Joint

26

Case Management Conference Statement and Rule 26(f) report and complete initial disclosures,

27

should be continued in accordance with the new case management conference date;

28

IT IS HEREBY STIPULATED AND AGREED by the parties, through their counsel,
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-CV-01958-RS
sf-3668390

1

1

subject to the approval of the Court, that the July 21, 2016 Case Management Conference is

2

continued to September 8, 2016 at 10:00 a.m. The parties shall meet and confer regarding initial

3

disclosures, early settlement, ADR process selection, and a discovery plan—as well as file their

4

ADR Certification and a Stipulation to ADR Process or Notice of Need for ADR Phone

5

Conference—21 days prior to that date, on August 18, 2016. The parties shall file their Rule

6

26(f) Report, complete initial disclosures, and file a Case Management Statement 7 days prior to

7

September 8, on September 1, 2016.

8
9

Dated: July 5, 2016

MORRISON & FOERSTER LLP

10
11
12
13
14
15
16
17

By: /s/ Tiffany Cheung
David F. McDowell
Tiffany Cheung
Alexandra E. Laks
425 Market Street
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant
SEAGATE TECHNOLOGY LLC

18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-CV-01958-RS
sf-3668390

2

1

Dated: July 5, 2016

GLANCY PRONGAY & MURRAY LLP

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

By: /s/ Mark S. Greenstone
Lionel Z. Glancy
Marc L. Godino
Mark S. Greenstone
1925 Century Park East, Suite 2100
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
BRAGAR EAGEL & SQUIRE, P.C.
David J. Stone (Pro Hac Vice)
Jeffrey H. Squire (Pro Hac Vice)
Lawrence P. Eagel (Pro Hac Vice)
885 Third Avenue, Suite 3040
New York, NY 10022
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs
EVERETT CASTILLO, LINDA CASTILLO,
WENDY TRAN, AND THE CLASS
KELLER GROVER LLP
Eric A. Grover
1965 Market Street
San Francisco, CA 94103
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
FINKELSTEIN, BLANKINSHIP, FREIPEARSON & GARBER, LLP
Jeremiah Frei-Pearson (Pro Hac Vice)
445 Hamilton Avenue, Suite 605
White Plains, NY 10601
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

24
25

Attorneys for Plaintiffs
NICHOLAS DATTOMA, FREDA LANG,
STEVEN WILK, AND THE CLASS

26
27
28
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-CV-01958-RS
sf-3668390

3

ECF ATTESTATION

1
2

I, Tiffany Cheung, am the ECF User whose ID and password are being used to file the

3

following STIPULATION AND [PROPOSED] ORDER CONTINUING CASE

4

MANAGEMENT CONFERENCE. In compliance with Local Rule 5-1(i)(3), I hereby attest that

5

Mark S. Greenstone has concurred in this filing.

6
7
8

Dated: July 5, 2016

DAVID F. MCDOWELL
TIFFANY CHEUNG
ALEXANDRA E. LAKS
MORRISON & FOERSTER LLP

9
10
11
12

By: /s/ Tiffany Cheung
TIFFANY CHEUNG
Attorneys for Defendant
SEAGATE TECHNOLOGY LLC

13
14
[PROPOSED] ORDER
15
PURSUANT TO STIPULATION, IT IS SO ORDERED.
16
17
18

DATED: _____________________, 2016 ______________________________________
7/5
HON. RICHARD SEEBORG
United States District Judge

19
20
21
22
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE
CASE NO. 3:16-CV-01958-RS
sf-3668390

4