Hanni v. American Airlines, Inc.

Filing 122

MODIFIED ORDER CHANGING TIME re 121 Stipulation. Signed by Judge Laporte on 3/9/09. (edllc1, COURT STAFF) (Filed on 3/9/2009)

Case 4:08-cv-00732-CW

Document 121

Filed 03/09/2009

Page 1 of 3

1 LOCKE LORD BISSELL & LIDDELL LLP MICHAEL V. POWELL (TX SBN 16204400) (appearance pro hac vzce)
2 mpowell(£lockelord.com

2200 Ross Avenue, Suite 2200
3 Dallas, Texas 75201-6776

Telephone: [phone]
4 Facsimile: [phone]

5 COOPER, WHITE & COOPER LLP STEPHEN KAUS (SBN 57454)
6
7j

skaus(£cwclaw. com

JIE-MING CHOU (SBN 211346) chou(£cwclaw. com 201 California Street, 1 ih Floor

8 San Francisco, California 94111

Telephone: [phone] Facsimile: [phone]

10 Attorneys for DEFENDANT AMRICAN AIRLINS, INC.
11

12 13 14

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

15 KATHLEEN HANI, individually and on
behalf of all others similarly situated,

CASE NO. C 08-00732 CW (EDL)

16 TIMOTHY T. HANI, CHASE L.
COSTELLO, and LANEN T. HANI, a

CHANGING TIME AS MODIFIED
Local Rule 6-2

STIPULA TED REQUEST FOR ORDER

17 minor, by and through his parent and Natural
Guardian, Kathleen Hanni,
18

Plaintiffs,
19

vs.

20

AMRICAN AIRLINS, INC., and DOES 1
21 through 20, inclusive,
22 23 24

Defendants.

Pursuant to Civil Local Rule 6-2, Plaintiffs Kathleen Hanni, Timothy Hanni, Chase

25 Costello, and Landen Hanni (collectively "Plaintiffs") and defendant American Airlines, Inc.

26 ("American") hereby stipulate and request that the Court issue an order changing time ("Order")

27 on American's Motion to Compel, fied with this Court on March 3,2009, which has not yet been
28 set by the Court for hearing. The parties request that American's Motion to Compel, along with
COOPER, WHITE & COOPER LLP
ATTORNEYS LAW AT 201 CALIFORNIASTREET SAN FRANCISCO, CA 94111

615489.1

C 08-00732 CW

STIPULATED REQUEST FOR ORDER CHANGING TIME

Case 4:08-cv-00732-CW

Document 121

Filed 03/09/2009

Page 2 of 3

1 American's Motion for Sanctions and Plaintiffs' Motion to Compel and Motion for Protective
2 Order (as detailed below) be heard by this Court on March 24,2009 at 9:00 a.m.
3
1.

Whereas, an order shortening time is necessary in this instance because the date by

4 which the Court has ordered the parties to complete all class certification discovery is April 16,
5 2009. (See Case Management Order, Docket #110.) The parties wish to have their motions

6 resolved with suffcient time before class certification discovery cutoff date for follow-up
7 discovery if necessary.

8

2.

Whereas, the parties request that the Court adopt the following shortened hearing

9 and briefing schedule on American's Motion to Compel:

10
11

a.

March 13, 2009 - deadline for Plaintiffs to fie opposition brief

b.
c.

March 18, 2009 - deadline for American to fie reply brief no later than 4:00 p.m.
March 24,2009 at 9:00 a.m. - hearing on American's Motion to Compel

12 13
3.

Whereas, American will fie its Motion for Sanctions pursuant to Local Rule 37-3

14 on March 11, 2009 and requests that its Motion for Sanctions be heard with its Motion to CompeL.

15 Plaintiffs also intend to fie a Motion to Compel against American relating to their Request for
16 Production of

Documents and a Motion for a Protective Order on March 11,2009 and request that

17 Plaintiffs' Motion to Compel and Motion for a Protective Order be heard on the same day and time

18 as American's Motion to Compel and Motion for Sanctions for the same reasons cited above. The
19 parties therefore request that the Court adopt the following shortened hearing and briefing

20 schedule on Plaintiffs' Motion to Compel and Motion for Protective Order and American's Motion

21 for Sanctions:
22
a.

March 1 1, 2009 - Plaintiffs to fie their Motion to Compel and Motion for a

23 Protective Order and American to fie its Motion for Sanctions.
24 25 26 27
4. b.
c.

March 18, 2009 - parties to fie their opposition briefs.

16

March 20, 2009 - parties to fie their reply briefs.

18

no later than 4:00 p.m.

d.

March 24,2009 at 9:00 a.m. - hearing on Plaintiffs' Motion to Compel;

No other time modifications related to these motions have been requested by the

28 parties.
COOPER, WHITE & COOPER LLP
ATTORNEYS LAW AT 201 CALIFORNIASTREET SAN FRANCISCO, CA 94111

615489.1

2
STIPULATED REQUEST FOR ORDER CHANGING TIME

C 08-00732 CW

Case 4:08-cv-00732-CW

Document 121

Filed 03/09/2009

Page 3 of 3

1

5.

The Order requested by the parties would not have an impact on any other dates set

2 by the Court in this case.
3

For the reasons stated above, the parties respectfully request that the Court grant their

4 stipulated request for order changing time so that Plaintiffs' and American's Motion to Compel and

5 American's Motion for Sanctions can be heard as expeditiously as possible.
6 DATED: March 9, 2009
7

COOPER, WHITE & COOPER LLP
By:

Isl

8 9

Jie-Ming Chou
Attorneys for Defendant American Airlines, Inc.

10 DATED: March 9, 2009
11

LAW OFFICES OF DAVID G. RAOS
By:

Isl
12 13 14 15 16 17 18 19

David Ramos Attorneys for Plaintiffs Kathleen Hanni, Timothy Hanni, Chase Costello, and Landen Hanni

UNIT ED

PURSUANT TO THIS STIPULATION, IT IS SO ORDERED.

20
21

N The Honorable Elizabeth D.T C T O F D I S Laporte RI United States Magistrate Judge

ER

22 23 24 25 26 27 28
COOPER, WHITE & COOPER LLP
ATTORNEYS LAW AT 201 CALIFORNIASTREET SAN FRANCISCO, CA 94111

615489.1

3

C 08-00732 CW

STIPULATED REQUEST FOR ORDER CHANGING TIME

A

C

LI

FO

D. La lizabeth Judge E

porte

R NIA

9 Dated: March -' 2009

S

ORDER

S DISTRICT TE C TA

D RDERE IS SO O FIED IT DI AS MO

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NO

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