Papasan et al v. Dometic Corporation et al

Filing 29

ORDER by Judge Haywood S. Gilliam, Jr. Granting 27 Stipulation to Exceed Page Limitations for Defendants' Motion to Dismiss. (ndrS, COURT STAFF) (Filed on 6/3/2016)

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LATHAM & WATKINS LLP
Peter A. Wald (Bar No. 85705)
Marcy C. Priedeman (Bar No. 258505)
505 Montgomery Street, Suite 2000
San Francisco, California
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendants
DOMETIC CORPORATION and DOMETIC LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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CATHERINE PAPASAN, NELSON
GOEHLE, ANDREW YOUNG, JIMMY
BYERS, CHRISTOPHER JOHNSTON, and
all persons similarly situated,

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Plaintiffs,

Case No. 3:16-cv-02117-HSG
UNOPPOSED MOTION, STIPULATION
AND ORDER TO EXCEED PAGE
LIMITATIONS FOR DEFENDANTS’
MOTION TO DISMISS

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vs.

The Honorable Haywood S. Gilliam, Jr.

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DOMETIC CORPORATION and
DOMETIC LLC,

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Defendants.
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ATTORNEYS AT LAW
SAN FRANCISCO

UNOPPOSED MOTION, STIPULATION AND [PROPOSED]
ORDER RE EXCEEDING PAGE LIMITATIONS
CASE NO. 3:16-cv-02117-HSG

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Pursuant to Local Rule 7-11 and with consent of Plaintiffs Catherine Papasan, Nelson

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Goehle, Andrew Young, Jimmy Byers, and Christopher Johnston (collectively, “Plaintiffs”),

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defendants Dometic Corporation and Dometic LLC (jointly, “Defendants”) hereby move the

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Court for leave to file a motion to dismiss that exceeds Local Rule 7-2(b)’s 25-page limitation by

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up to 10 pages.

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In support of their unopposed motion, Defendants state as follows:

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WHEREAS, on April 21, 2016, Plaintiffs filed their 82-page Class Action Complaint (the

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“Complaint”), which contains 367 separately numbered paragraphs;

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WHEREAS, on June 17, 2016, Defendants intend to file a joint motion to dismiss each of

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Plaintiffs’ 21 claims on the ground that each of these claims—arising under Federal law and four

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separate states’ laws—fail to state a claim upon which relief can be granted (the “Motion”);

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WHEREAS, although Defendants endeavor to keep their joint Motion as brief as

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possible, Defendants cannot adequately address each of their arguments in the 25 pages afforded

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by Local Rule 7-2(b);

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WHEREAS, Defendants submit that their Motion is concise, free of repetition, and

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addresses only pertinent points and authorities, but that an additional 10 pages is needed to fully

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address each of the foregoing arguments and supporting authority; and

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WHEREAS, counsel for the parties have conferred and have agreed that Defendants may
exceed the page limitation in Local Rule 7-2(b) by 10 pages.

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Accordingly, IT IS HEREBY STIPULATED AND AGREED between the parties, by

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and through their counsel of record, that Defendants may exceed the page limitation in Local

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Rule 7-2(b) by 10 pages.

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ATTORNEYS AT LAW
SAN FRANCISCO

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UNOPPOSED MOTION, STIPULATION AND [PROPOSED]
ORDER RE EXCEEDING PAGE LIMITATIONS
CASE NO. 3:16-cv-02117-HSG

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IT IS SO STIPULATED.

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Dated: June 2, 2016

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LATHAM & WATKINS LLP
Peter A. Wald
Marcy C. Priedeman

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By: /s/ Marcy C. Priedeman

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505 Montgomery St., Suite 2000
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Counsel for Defendants Dometic Corporation and
Dometic LLC

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Dated: June 2, 2016

HAGENS BERMAN SOBOL SHAPIRO LLP
Steve W. Berman (pro hac vice )
Thomas E. Loeser
Ashley A. Bede (pro hac vice)

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By: /s/ Ashley A. Bede
1918 Eight Avenue, Suite 3300
Seattle, WA 998101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
HAGENS BERMAN SOBOL SHAPIRO LLP
Jeff D. Friedman
715 Hearst Avenue, Suite 202
Berkeley, CA 94710
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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ATTORNEYS AT LAW
SAN FRANCISCO

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UNOPPOSED MOTION, STIPULATION AND [PROPOSED]
ORDER RE EXCEEDING PAGE LIMITATIONS
CASE NO. 3:16-cv-02117-HSG

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LAW OFFICES OF TERRENCE A. BEARD
Terrence A. Beard
525 Marina Blvd.
Pittsburg, CA 94565
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Counsel for Plaintiffs and the Proposed Class

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Pursuant to Civil Local Rule 5-1(i)(3), counsel for Defendants has obtained the
concurrence of Plaintiffs’ counsel, Ashley A. Bede, in the filing of this stipulation.

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Dated: June 2, 2016

/s/ Marcy C. Priedeman

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED except that the
Defendants may exceed the page limitation in Local Rule 7-2(b) by 5 pages.

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Dated: June 3, 2016
The Honorable Haywood S. Gilliam, Jr.
United States District Judge

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ATTORNEYS AT LAW
SAN FRANCISCO

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UNOPPOSED MOTION, STIPULATION AND [PROPOSED]
ORDER RE EXCEEDING PAGE LIMITATIONS
CASE NO. 3:16-cv-02117-HSG