Smith v. Express Scripts Holding Company

Filing 21

ORDER Granting 20 Joint Stipulation to Continue Case Management Conference & Proposed Order. Signed by Judge Vince Chhabria on 12/2/2016. (vclc2S, COURT STAFF) (Filed on 12/2/2016)

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BARRY C. MARSH, ESQ. (SB#99908)
SCOTT R. KANTER, ESQ. (SB#199696)
Hinshaw, Marsh, Still & Hinshaw LLP
12901 Saratoga Avenue
Saratoga, CA 95070
[phone]
[e-mail]
MICHAEL P. NOLAN, ESQ. (pro hac vice)
TANYA M. MAERZ, ESQ. (pro hac vice)
Husch Blackwell LLP
190 Carondelet Plaza, Suite 600
St. Louis, MO 63105
[phone]
[e-mail]
[e-mail]
Attorneys for Defendant Express Scripts Holding Company

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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)
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Plaintiff,
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vs.
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EXPRESS SCRIPTS HOLDING COMPANY, )
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Defendant.
MICHAEL SMITH

Case No.: 3:16-cv-05001-VC
JOINT STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE &
PROPOSED ORDER

Complaint Filed: July 1, 2016

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Plaintiff MICHAEL SMITH and Defendant EXPRESS SCRIPTS HOLDING
COMPANY (collectively, the “Parties”), through their respective counsel and subject to the
approval of the Court, hereby STIPULATE AND AGREE that:
1.

The Parties previously submitted a Joint Case Management Statement and

Discovery Plan to the Court pursuant to the Court’s Order.

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2.

Due to business travel and scheduling conflicts as well as continued discussions

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amongst the Parties, the Parties respectfully request the Court continue the Case Management

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Conference presently set for December 6, 2016 until a later date after January 13, 2017 to be

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determined by the Court.
3.

The Parties have not requested a prior continuance of the Case Management

Conference. This joint stipulation for continuance is not made for the purpose of vexation or

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delay, but for the sole purpose of pursuing an efficient resolution to this dispute. The requested

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continuance will serve the interests of justice and conserve judicial resources.

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WHEREFORE, Plaintiff and Defendant respectfully request that this Court enter an
Order granting a continuance of the Case Management Conference from December 6, 2016 to a
date after January 13, 2017 to be determined by the Court.
Dated: December 1, 2016

/s/ David Shane
DAVID SHANE
Counsel for Plaintiff Michael Smith

Dated: December 1, 2016

/s/ Barry Marsh
BARRY MARSH
SCOTT KANTER
MICHAEL NOLAN
TANYA MAERZ
Counsel for Defendant Express Scripts Holding
Company

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IT IS SO ORDERED.
Dated: December 2, 2016

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UNITED STATES DISTRICT JUDGE, HONORABLE
VINCE CHHABRIA

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