Deras v. Volkswagen Group of America, Inc.

Filing 50

STIPULATION AND ORDER re 48 STIPULATION WITH PROPOSED ORDER CONTINUING CASE MANAGEMENT CONFERENCE filed by Volkswagen Group of America, Inc. Case Management Statement due by 7/23/2018. Initial Case Management Conference set for 8/1/2018 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor.. Signed by Judge Jon S. Tigar on May 21, 2018. (wsn, COURT STAFF) (Filed on 5/21/2018)

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HERZFELD & RUBIN, P.C.
Michael B. Gallub (Admitted Pro Hac Vice)
E-mail: [e-mail]
Jeffrey L. Chase (Admitted Pro Hac Vice)
E-mail: [e-mail]
125 Broad Street
New York, N.Y. 10004
Telephone [phone]; Facsimile [phone]
HERZFELD & RUBIN LLP
Craig L. Winterman (Bar No. 75220)
E-mail: [e-mail]
10866 Wilshire Blvd., Suite 800
Los Angeles CA 90024
Telephone: [phone]; Facsimile: [phone]
Counsel for Defendant Volkswagen Group of America, Inc.
THE LAW OFFICE OF STEPHEN M. HARRIS, P.C.
Stephen M. Harris (SBN 110626)
E-mail: [e-mail]
6230 Canoga Avenue, Suite 1500
Woodland Hills, California 91367
Tel: [phone]; Facsimile: [phone]
Counsel for Plaintiff Rosaura Deras

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ROSAURA DERAS, individually and on
behalf of a class of similarly situated
individuals,

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Plaintiffs,

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vs.

Case No.: 17-cv-05452- JST
AND ORDER
STIPULATION CONTINUING CASE
MANAGEMENT CONFERENCE
Judge: Jon S. Tigar

VOLKSWAGEN GROUP OF AMERICA,
INC.,
Defendant.

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STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE

CASE NO. 3:17-CV-05452 -JST

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WHEREAS on September 20, 2017, Plaintiff Rosaura Deras (“Plaintiff”) filed her
Complaint;
WHEREAS on November 13, 2017, pursuant to a stipulated extension of time, Defendant
filed a motion to dismiss Plaintiff’s Complaint;
WHEREAS on November 24, 2017, Plaintiff filed a First Amended Complaint;

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WHEREAS, pursuant to a stipulated extension of time, Defendant filed a motion to
dismiss the First Amended Complaint on January 15, 2018;
WHEREAS on May 16, 2018, the Court sua sponte continued the Case Management
Conference that was scheduled for May 23, 2018 to July 18, 2018, due to the court’s
forthcoming order on Defendant’s motion to dismiss;
WHEREAS on May 17, 2018, the Court issued its Order granting in part and denying in
part Defendant’s motion to dismiss;
WHEREAS because counsel for Defendant has a prior travel commitment prior to and on
July 18, 2018, counsel for all parties have agreed, subject to the Court’s approval, to continue the
July 18, 2018 Case Management Conference to July 25, 2018, or if that date is not available, to
such other date thereafter that is convenient to the Court;
WHEREAS the agreed-to continuance will not prejudice any party, nor will it otherwise
alter the date of any event or deadline already fixed by Court order, and this stipulated request is
being filed at least 14 days before the scheduled conference as required by Rule 6-1(b) of the
Local Civil Rules of the United States District Court for the Northern District of California;
THEREFORE, pursuant to Civil L.R. 6-1(b) and 6-2, it is hereby stipulated by and
between Plaintiff and Defendant, through their respective counsel, that the Case Management
Conference be continued to July 25, 2018, or if that date is not available, to such other date
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STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE

CASE NO. 3:17-CV-05452 -JST

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thereafter that is convenient for the Court, and that the July 11, 2018 date for filing an updated
Joint Case Management Statement be adjusted accordingly.
IT IS SO STIPULATED.

Dated: May 17, 2018

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HERZFELD & RUBIN P.C.

By:

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/s/ Michael Gallub
Michael B. Gallub (Pro hac vice)
Attorney for Defendant,
VOLKSWAGEN GROUP OF AMERICA,
INC.

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Dated: May 17, 2018

THE LAW OFFICE OF STEPHEN M. HARRIS,
P.C.

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By:

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/s/ Stephen M. Harris
Stephen M. Harris (SBN 110626)
Attorney for Plaintiff,
ROSAURA DERAS

PURSUANT TO STIPULATION, IT IS SO ORDERED:
The Case Management Conference is continued to

August 1, 2018.

The Parties shall file an updated Joint Case Management Statement by

July 23, 2018.

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Dated: May 21, 2018

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Honorable Jon S. Tigar
United States District Court Judge

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STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE

CASE NO. 3:17-CV-05452 -JST