Kelly v. Bay Area Toll Authority et al

Filing 21

STIPULATION AND ORDER Regarding Briefing Schedule On Defendants' motions to dismiss. Signed by Judge Richard Seeborg on 1/25/17. (cl, COURT STAFF) (Filed on 1/25/2017)

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LINDEMANN LAW FIRM, APC
BLAKE J. LINDEMANN, SBN 255747
PO SATIA WAGHALTER, SBN 236612
433 N. Camden Drive, 4th Floor
Beverly Hills, CA 90210
Telephone: [phone]
Facsimile: [phone]
E-Mail:
[e-mail]
Attorneys For Plaintiff
MICHELLE KELLY AND THE INTERIM CLASS

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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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MICHELLE KELLY, an individual, on behalf
of herself and those similarly situated,

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v.

Case No. 3:16-cv-06837-RS
JOINT STIPULATION REGARDING
BRIEFING SCHEDULE ON
DEFENDANTS’ MOTIONS TO DISMISS;
[PROPOSED] ORDER

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BAY AREA TOLL AUTHORITY; GOLDEN
GATE BRIDGE, HIGHWAY AND
TRANSPORTATION DISTRICT; XEROX
STATE AND LOCAL SOLUTIONS, INC., and
DOES 1-100,

[PRIVACY CLASS ACTION]

The Honorable Richard Seeborg

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Defendants.
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CASE NO. 16-cv-06837-RS
STIPULATION AND ORDER

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STIPULATION

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This Stipulation is entered into by and between lead plaintiff, Michelle Kelly (“Plaintiff”)

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and defendants Bay Area Toll Authority, Golden Gate Bridge, Highway and Transportation

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District, and Xerox State and Local Solutions, Inc. (collectively, the “Defendants”) by and

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through their respective attorneys of record.

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WHEREAS, Plaintiff’s Class Action Complaint (“Complaint”) was removed to this
Court on November 28, 2016;

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WHEREAS, on January 6, 2016, each of the Defendants filed a Motion to Dismiss the
Complaint (collectively, the “Motions”);

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WHEREAS pursuant to Northern District of California Local Rules 7-2 and 7-3, the

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Parties agree that this Motion involves several questions of law requiring an extended period by

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which the parties may respond and reply;

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IT IS HEREBY STIPULATED, pursuant to Northern District of California Local Rules
7-2 and 7-3, by and between the undersigned counsel for the parties that:

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Plaintiff’s oppositions to the Motions (or an amended pleading) shall be filed on or before
February 3, 2017;

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Defendants’ replies in support of their Motions shall be filed on or before February 16,
2017;
IT IS FURTHER STIPULATED, that by entering into this Stipulation, Defendants are

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not waiving their right to seek a stay of all discovery in this matter pending the Court’s ruling on

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Defendants’ Motions to Dismiss, including a stay on providing initial disclosures and engaging

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in a Rule 26(f) conference.

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DATED: January 19, 2017

LINDEMANN LAW FIRM, APC

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/s/ Blake J. Lindemann
BLAKE J. LINDEMANN
Attorneys for Plaintiff
MICHELLE KELLY

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CASE NO. 16-cv-06837-RS
STIPULATION AND ORDER

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DATED: January 19, 2017

LAW OFFICES OF DAREN SCHLECTER

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/s/ Daren M. Schlecter
DAREN M. SCHLECTER
Attorneys for Plaintiff
MICHELLE KELLY

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DATED: January 24, 2017

LAFAYETTE & KUMAGAI LLP

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/s/
REBECCA K. KIMURA
Attorney for Defendants
XEROX STATE AND LOCAL SOLUTIONS,
INC.

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DATED: January 19, 2017

HANSON BRIDGETT LLP

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/s/
SAMANTHA D. WOLFF
Attorney for Defendants
GOLDEN GATE BRIDGE, HIGHWAY AND
TRANSPORTATION DISTRICT AND BAY
AREA TOLL AUTHORITY

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CASE NO. 16-cv-06837-RS
STIPULATION AND ORDER

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ECF ATTESTATION

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I, Blake J. Lindemann, am the ECF User whose ID and Password are being used to file this

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document. I attest that concurrence in the filing of this document has been obtained from the

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signatories.

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DATED: January 24, 2017

LINDEMANN LAW FIRM, APC

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/s/ Blake J. Lindemann
BLAKE J. LINDEMANN

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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1/25
Dated: ____________, 2017

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___________________________________
THE HONORABLE RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE

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CASE NO. 16-cv-06837-RS
STIPULATION AND ORDER

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