Rhom v. Thumbtack, Inc.
Filing
26
ORDER by Judge Haywood S. Gilliam, Jr. Denying 25 Stipulation to Continue Case Management Conference. (ndrS, COURT STAFF) (Filed on 7/19/2016)
1 ANTHONY J. ORSHANSKY, Cal. Bar No.199364
anthony@counselonegroup.com
2 ALEXANDRIA R. KACHADOORIAN, Cal. Bar No. 240601
alexandria@counselonegroup.com
3
JUSTIN KACHADOORIAN, Cal. Bar No. 260356
4 justin@counselonegroup.com
COUNSELONE, P.C.
5 9301 Wilshire Boulevard, Suite 650
Beverly Hills, California 90210
6 Telephone: (310) 277-9945
Facsimile: (424) 277-3727
7
8 Attorneys for Plaintiff MICHAEL RHOM,
on behalf of himself and others similarly situated
9
[Additional parties and counsel on signature
10 page]
11
12
UNITED STATES DISTRICT COURT
13
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
14
15 MICHAEL RHOM, on behalf of himself and
other similarly situated,
16
Plaintiff,
17
vs.
18
THUMBTACK, INC., a Delaware corporation
19 and DOES 1 through 50, inclusive,
20
Case No. 3:16-cv-02008-HSG
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER
Judge: Hon. Haywood S. Gilliam, Jr.
Defendant.
21
22
Plaintiff MICHAEL RHOM, and Defendant THUMBTACK, INC., through their
23 respective counsel of record, and without admission of any kind, or waiver of any defense,
24 objection, or other response, hereby stipulate and agree as follows:
25
WHEREAS, Plaintiff filed his Complaint in the Superior Court of the State of
26 California in and for the County of San Francisco on March 22, 2016;
27
WHEREAS, Plaintiff served Defendant with the Summons and Complaint on April
28 11, 2016;
3:16-cv-02008-HSG
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
1
WHEREAS, Defendant removed this action to this Court on April 15, 2016;
2
WHEREAS, Defendant filed its Motion to Dismiss, Or, in the Alternative, Stay the
3 Complaint (“Motion”) on June 2, 2016;
WHEREAS, Plaintiff filed his response in opposition to Defendant’s Motion on
4
5 June 23, 2016;
6
WHEREAS, Defendant filed its reply in support of the Motion on July 7, 2016;
7
WHEREAS, the hearing on Defendant’s Motion is set for August 4, 2016, at 2:00
8 p.m.;
9
WHERAS, the Case Management Conference is currently set for tomorrow, July
10 19, 2016, at 2:00 p.m.;
11
WHEREAS, the parties filed their Joint Case Management Statement on July 12,
12 2016, in compliance with the Court’s Civil Standing Order [see ECF No. 24];
13
WHEREAS, Plaintiff’s counsel on July 18, 2016 contacted Defendant’s counsel
14 and requested a continuance of the Case Management Conference set for July 19, 2016, to August
15 4, 2016, at 2:00 p.m. to coincide with the hearing on the Motion;
16
WHEREAS, Defendant has agreed to Plaintiff’s request;
17
WHEREAS, Local Civil Rule 6-2(a) permits the parties to “file a stipulation,
18 conforming to Civil L.R. 7-12, requesting an order changing time that would affect the date of an
19 event or deadline already fixed by Court order[]”;
20
WHEREAS, a continuance of the Case Management Conference to coincide with
21 the hearing on the Motion serves the interests of judicial economy by minimizing the expenditure
22 of the Court’s and parties’ time and costs, including travel costs;
23
WHEREAS the Court previously granted two time modifications in this case,
24 extending Defendant’s time to respond to the Complaint from May 2, 2016 to June 2, 2016 [ECF
25 No. 11], and extending the parties’ deadline to file a response in opposition to, and reply in
26 support of, the Motion [ECF No. 15];
27
WHEREAS, granting the requested time modification will not adversely affect the
28 schedule for this case because the parties have already conducted their Rule 26(f) conference [see
3:16-cv-02008-HSG
-2STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
1 ECF No. 24] and ADR phone conference [ECF No. 23] and have begun discovery;
2
NOW THEREFORE, Plaintiff and Defendant, through their counsel of record,
3 stipulate to the following:
4
IT IS HEREBY STIPULATED that the Case Management Conference currently
5 scheduled for July 19, 2016 at 2:00 p.m. shall be continued to August 4, 2016 at 2:00 p.m. to
6 coincide with the hearing on the Motion.
7
8 DATED: July 18, 2016
9
10
COUNSELONE, PC
ANTHONY J. ORSHANSKY
ALEXANDRIA R. KACHADOORIAN
JUSTIN KACHADOORIAN
By: /s/ Anthony J. Orshansky
ANTHONY J. ORSHANSKY
Attorneys for Plaintiff MICHAEL RHOM
11
12
13
14 DATED: July 18, 2016
15
MUNGER, TOLLES & OLSON LLP
JONATHAN H. BLAVIN
ANKUR MANDHANIA
16
By: /s/ Jonathan H. Blavin
JONATHAN H. BLAVIN
Attorneys for THUMBTACK, INC.
17
18
19
ECF ATTESTATION
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I, Anthony J. Orshansky, am the ECF User whose ID and password are being used
to file this document. In compliance with Local Rule 5-1(i)(3), I hereby attest that the above
defense counsel has concurred in and authorized this filing, and I shall maintain records to support
this concurrence for subsequent production for the Court if so ordered or for inspection upon
request by a party.
/s/ Anthony J. Orshansky
Anthony J. Orshansky
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3:16-cv-02008-HSG
-3STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
E
AT
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
S
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ER
illiam J
r.
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J u d ge
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NO
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____________________________________
R NIA
____________________________
D
DENIE
Hon. Haywood S. Gilliam, Jr.
UNITED STATES DISTRICT COURT
JUDGE
FO
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7/19/2016
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3:16-cv-02008-HSG
-4STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
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