Taragan et al v. Nissan North America, Inc. et al

Filing 84

STIPULATION AND ORDER re 82 STIPULATION WITH PROPOSED ORDER EXTENDING BRIEFING DEADLINES filed by Nissan North America, Inc., Helen Taragan, Marites Asido, Matthew Wakefield, Set/Reset Deadlines as to 82 STIPULATION WITH PROPOSE D ORDER EXTENDING BRIEFING DEADLINES, 75 MOTION to Dismiss . Responses due by 1/29/2013. Replies due by 2/26/2013. Motion Hearing set for 3/12/2013 01:00 PM before Hon. Saundra Brown Armstrong.. Signed by Judge ARMSTRONG on 12/17/12. (lrc, COURT STAFF) (Filed on 12/17/2012)

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Elizabeth J. Cabraser (SBN 083151)
Scott P. Nealey (SBN 193062)
Jahan C. Sagafi (SBN 224887)
Joseph P. Forderer (SBN 278774)
LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, CA 94111-3339
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiffs and proposed Class Members

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John H. Beisner (admitted pro hac vice)
Jessica D. Miller (admitted pro hac vice)
SKADDEN, ARPS, SLATE, MEAGHER
& FLOM LLP
1440 New York Avenue NW
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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Counsel For Defendant Nissan North America, Inc.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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HELEN TARAGAN, FRANCES
JEANETTE TAYLOR, and CLARENCE
TAYLOR, on behalf of themselves and all
others similarly situated,

Case No. C-09-03660 SBA
STIPULATION AND ORDER
EXTENDING BRIEFING DEADLINES

Plaintiffs,

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v.

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NISSAN NORTH AMERICA, INC., a
California corporation; and NISSAN
MOTOR COMPANY, LTD., a Japanese
company

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Defendants.
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1071631.1

CASE NO. C-09-03660 SBA
STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING DEADLINES

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WHEREAS, Nissan North America, Inc. (“Nissan”) filed a Motion To Dismiss Plaintiffs’

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First Amended Complaint (the “Motion”) on November 27, 2012, setting a hearing date of

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January 29, 2013;

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WHEREAS, under the Local Rules and as stated in the text of Docket No. 75, Plaintiffs’

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response (the “Opposition”) was originally due by December 11, 2012, and Nissan’s reply (the

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“Reply”) is due by December 18, 2012;

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WHEREAS, counsel for both Plaintiffs and Nissan had scheduling conflicts due to the
press of other previously pending matters and vacations;

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WHEREAS, on December 3, 2012, the parties jointly requested that (1) Plaintiffs’

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deadline to file their Opposition be extended to December 21, 2012, and (2) Nissan’s deadline to

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file its Reply is January 15, 2013, and on December 7, 2012, the Court granted that request; and

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WHEREAS, due to a sudden medical emergency, Plaintiffs’ counsel require additional
time to complete their Opposition brief.

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Accordingly, the parties hereby stipulate and agree that (1) Plaintiffs’ deadline to file

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their Opposition be extended to January 29, 2013, (2) Nissan’s deadline to file its Reply be

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extended to February 26, 2013, and (3) the hearing be continued to March 12, 2013.

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Dated: December 14, 2012

LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP

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/s/ Jahan C. Sagafi
Jahan C. Sagafi

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Attorneys for Plaintiffs and proposed Class

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Dated: December 14, 2012

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SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
/s/ John H. Beisner
John H. Beisner

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Attorneys for Defendant

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1071631.1

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CASE NO. C-09-03660 SBA

STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING DEADLINES

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.

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Dated: December 17, 2012

__________________________________
The Honorable Saundra Brown Armstrong
United States District Court

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1071631.1

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CASE NO. C-09-03660 SBA

STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING DEADLINES