Mazzini et al v. Norwegian Air Shuttle ASA

Filing 22

STIPULATION AND ORDER re 21 Extending All Deadlines filed by Norwegian Air Shuttle ASA. Case Management Statement due by 9/6/2018. Initial Case Management Conference reset for 9/13/2018 09:30 AM in San Francisco, Courtroom 05, 17th Floor. Signed by Judge Edward M. Chen on 6/22/18. (bpf, COURT STAFF) (Filed on 6/22/2018)

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PILLSBURY WINTHROP SHAW PITTMAN LLP
JACOB R. SORENSEN (CA Bar No. 209134)
[e-mail]
JOHN M. GRENFELL (CA Bar No. 88500)
john.grenfell@pillsburylawcom
WILLIAM T. PALMER (CA Bar No. 312923)
[e-mail]
Four Embarcadero Center, 22nd Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
NORWEGIAN AIR SHUTTLE ASA

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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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BRIDGET MAZZINI, PATRICIA J.
PAWLAK, and JOESEPH ANDRIS on
behalf of themselves and all other similarly
situated,
Plaintiffs,

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vs.

Case No. 3:18-cv-01574-EMC
STIPULATION TO EXTEND
DEFENDANT’S DEADLINE TO
RESPOND TO PLAINTIFFS’
COMPLAINT AND CONTINUE CASE
MANAGEMENT CONFERENCE AND
ALL RELATED DEADLINES

NORWEGIAN AIR SHUTTLE ASA,
Defendant.

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WHEREAS, Plaintiffs Bridget Mazzini, Patricia J. Pawlak, and Joeseph Andris

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(“Plaintiffs”) filed a Complaint against Defendant Norwegian Air Shuttle ASA

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(“Norwegian Air”) on March 13, 2018, and served Norwegian Air with their Complaint on

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or around March 23, 2018;

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WHEREAS, on April 6, 2018, the parties submitted a stipulation extending

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Norwegian Air’s deadline to respond to the Complaint to June 15, 2018 (Dkt. 10);

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WHEREAS, on May 23, 2018 this matter was reassigned to Judge Edward M. Chen
for all further proceedings (Dkt. 19);

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STIPULATION EXTENDING CMC AND
NORWEGIAN AIR’S TIME TO
RESPOND TO COMPLAINT
Case No. 3:18-cv-01574-EMC

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WHEREAS, on May 31, 2018, the Court rescheduled the Case Management
Conference from June 12, 2018 to July 12, 2018 (Dkt. 20); and
WHEREAS, the parties are currently engaged in settlement discussions with the

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hope of reaching a resolution without the need for further litigation and would like to avoid

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the time and expense of litigation activities while they complete those discussions;

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NOW, THEREFORE, IT IS HEREBY STIPULATED between Plaintiffs and
Norwegian Air, through their respective counsel, that:
1. Norwegian Air shall have an extension of time up to and including September 7,
2018, to answer or otherwise respond to Plaintiffs’ Complaint.
2. The Case Management Conference currently scheduled for July 12, 2018 is

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rescheduled for September 13, 2018, or another date that is convenient for the

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Court.

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3. Consistent with the Court’s May 31, 2018 scheduling order (Dkt. 20), the parties

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shall file a joint case management conference statement one week in advance of

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the new Case Management Conference date.

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4. Pursuant to the Court’s March 14, 2018 scheduling order (Dkt. 5), all other
deadlines are continued accordingly, as follows:
a. 21 days before the new Case Management Conference shall be the last
day for the parties to:
i. meet and confer re initial disclosures, early settlement, ADR
process selection, and discovery plan;

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ii. file ADR Certification signed by Parties and Counsel; and

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iii. file either Stipulation to ADR Process or Notice of Need for

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ADR Phone Conference.
b. 7 days before the new Case Management Conference shall be the last
day for the parties to:
i. file Rule 26(f) Report; and

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STIPULATION EXTENDING CMC AND
NORWEGIAN AIR’S TIME TO
RESPOND TO COMPLAINT
Case No. 3:18-cv-01574-EMC

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ii. complete initial disclosures or state objection in Rule 26(f)
Report.
Dated: June 13, 2018.
PILLSBURY WINTHROP SHAW PITTMAN LLP
JACOB R. SORENSEN
Four Embarcadero Center, 22nd Floor
San Francisco, CA 94111

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By:

/s/ Jacob R. Sorensen
Jacob R. Sorensen

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Attorneys for Defendant
NORWEGIAN AIR SHUTTLE ASA

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CORNERSTONE LAW GROUP
GORDON W. RENNEISEN
351 California Street, Suite 600
San Francisco, CA 94104

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By:

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/s/ Gordon W. Renneisen
Gordon W. Renneisen

Attorneys for Plaintiffs

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ATTESTATION STATEMENT

behalf the filing is submitted, concurs in the filing’s content and has authorized the filing.
Dated: June 13, 2018.

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/s/ Jacob R. Sorensen
Jacob R. Sorensen

O
IT IS S

ED

ORDER

U.S. District Judge Edward M. Chen
. Chen

dward M
Judge E

NO

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UNIT
ED

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IT IS SO ORDERED.
June 22, 2018
Dated:

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Pursuant to Civil L.R. 5-1(i)(3), I attest that the other signatory listed, and on whose

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N

C
F
DSTIPULATION EXTENDING CMC AND
IS T RIC T O
NORWEGIAN AIR’S TIME TO
RESPOND TO COMPLAINT
Case No. 3:18-cv-01574-EMC