Dennis M. Lorenz v. Safeway, Inc. et al

Filing 72

STIPULATION AND ORDER re 71 STIPULATION WITH PROPOSED ORDER to Continue Further Case Management Conference filed by Safeway Benefit Plans Committee, Safeway, Inc. Case Management Statement due by 10/2/2017. Further Case Management Conference set for 10/11/2017 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on August 30, 2017. (wsn, COURT STAFF) (Filed on 8/30/2017)

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R. Bradford Huss, SBN 71303
Angel L. Garrett, SBN 255682
Dylan D. Rudolph, SBN 278707
TRUCKER  HUSS
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail]
[e-mail]
[e-mail]

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Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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Joseph C. Faucher, SBN 137353
TRUCKER  HUSS
A Professional Corporation
633 W. 5th Street, 26th Floor
Los Angeles, California 90071
Telephone: [phone]
Facsimile:
[phone]
E-mail: [e-mail]
Attorneys for Defendants
SAFEWAY INC. and SAFEWAY BENEFIT
PLANS COMMITTEE

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO

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DENNIS M. LORENZ, Individually and On
Behalf of All Others Similarly Situated,

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Plaintiff,
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Case No. 3:16-cv-04903-JST
STIPULATION FOR AN ORDER
CONTINUING CASE MANAGEMENT
CONFERENCE TO OCTOBER 11, 2017

vs.
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SAFEWAY, INC.; SAFEWAY BENEFIT
PLANS COMMITTEE; GREAT-WEST
FINANCIAL RPS LLC; and DOES 1 through
50, inclusive,
Defendants.

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STIPULATION FOR AN ORDER CONTINUING CASE MANAGEMENT CONFERENCE;
Case No. 3:16-CV-04903-JST
166210.v1

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Pursuant to Local Rule 6-1(b), Defendants SAFEWAY INC. and SAFEWAY BENEFIT

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PLANS COMMITTEE (collectively, “Safeway Defendants”) and Plaintiff DENNIS M. LORENZ

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(“Plaintiff”) (Plaintiff and Safeway Defendants collectively referred to as the “Parties”) hereby

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stipulate and request, by and through their respective counsel, an order continuing the further case

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management conference that is currently set in this litigation to October 11, 2017 at 2:00 p.m.:

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WHEREAS, a further case management conference is currently set in this action for

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September 13, 2017 at 2:00 p.m., with an updated joint case management statement due by

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September 5, 2017 (Docket No. 61);

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Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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WHEREAS, this case was deemed “related” to another case currently pending before the
Court, titled Maria Karla Terraza v. Safeway Inc., et al. (No. 16-cv-03994-JST) (Docket No. 26);

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WHEREAS, a further case management conference was previously set in the Maria Karla
Terraza action for September 13, 2017 (Case No. 16-cv-03994 Docket No. 66);

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WHEREAS, on August 25, 2017, the Clerk issued a notice continuing the case management

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conference in the Maria Karla Terraza case to October 11, 2017 at 2:00 p.m., with an updated joint

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case management statement due by October 2, 2017 (Case No. 16-cv-03994 Docket No. 91);

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WHEREAS, the Parties have agreed that good cause exists for an order continuing the

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further case management conference currently set in this case, to the October 11, 2017 at 2:00 p.m.

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continued date set in the Terraza action because issues may be addressed at both conferences that

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affect both of these related cases, and that an updated joint case management statement will be due

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in this action by October 2, 2017 accordingly;

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STIPULATION FOR AN ORDER CONTINUING CASE MANAGEMENT CONFERENCE;
Case No. 3:16-CV-04903-JST
166210.v1

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NOW, THEREFORE, the Parties hereby stipulate and request as follows:

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That the Court issue an order continuing the further case management conference

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currently set in this action to the October 11, 2017 at 2:00 p.m., and that an updated

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joint case management statement will be due by October 2, 2017.

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IT IS SO STIPULATED.

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DATED: August 30, 2017

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By: /s/ Joseph C. Faucher
R. Bradford Huss
Joseph C. Faucher
Attorneys for Defendants
SAFEWAY INC. and SAFEWAY BENEFIT
PLANS COMMITTEE

Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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TRUCKER  HUSS

DATED: August 30, 2017

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SCHNEIDER, WALLACE, COTTRELL, KONECKY,
WOTKYNS, LLP
By: /s/ Kyle G. Bates
Jason H. Kim
Kyle G. Bates
Attorneys for Plaintiff
DENNIS M. LORENZ, individually and on behalf
of the SAFEWAY 401(K) PLAN

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I attest that my firm has obtained Kyle G. Bates’s concurrence in the filing of this document.

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DATED: August 30, 2017

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TRUCKER  HUSS

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By: /s/ Joseph C. Faucher
R. Bradford Huss
Joseph C. Faucher
Attorneys for Defendants
SAFEWAY INC. and BENEFIT PLANS
COMMITTEE SAFEWAY INC.

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STIPULATION FOR AN ORDER CONTINUING CASE MANAGEMENT CONFERENCE;
Case No. 3:16-CV-04903-JST
166210.v1

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[PROPOSED] ORDER

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Good cause exists for an order continuing the further case management conference currently

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set in this action for September 13, 2017. The further case management conference is hereby

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continued to October 11, 2017 at 2:00 p.m. An updated joint case management statement is due by

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October 2, 2017.

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DATE: August 30

, 2017
Hon. Jon S. Tigar
United States District Court Judge

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Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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STIPULATION FOR AN ORDER CONTINUING CASE MANAGEMENT CONFERENCE;
Case No. 3:16-CV-04903-JST
166210.v1

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