Bullen v. Citigroup Global Markets, Inc.

Filing 48

STIPULATION AND CASE MANAGEMENT SCHEDULING ORDER: Jury Trial set for 2/6/2012 08:30 AM before Hon. Saundra Brown Armstrong. Motions due by 11/15/2011. Pretrial Conference set for 1/17/2012 01:00 PM before Hon. Saundra Brown Armstrong.. Signed by Judge ARMSTRONG on 8/16/11. (lrc, COURT STAFF) (Filed on 8/16/2011)

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DARYL S. LANDY, State Bar No. 136288
SHWETA GERA, State Bar No. 234627
MORGAN, LEWIS & BOCKIUS LLP
2 Palo Alto Square
3000 El Camino Real, Suite 700
Palo Alto, CA 94306-2122
Telephone: [phone]
Facsimile: 650.843.4001
E-mail: [e-mail];
[e-mail]
GEORGE A. STOHNER, State Bar No. 214508
MORGAN, LEWIS & BOCKIUS LLP
300 South Grand Avenue
Twenty-Second Floor
Los Angeles, CA 90071-3132
Telephone: [phone]
Facsimile: 213.612.2501
E-mail: [e-mail]
Attorneys for Defendant
CITIGROUP GLOBAL MARKETS INC.
DAVID M. MEDBY, State Bar No. 227401
GENE WILLIAMS, State Bar No. 211390
SANG PARK, State Bar No. 232956
MARK ESTRELLA, State Bar No. 187091
INITIATIVE LEGAL GROUP, APC
1800 Century Park East, 2nd Floor
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: 310.861.9051
E-mail: [e-mail];
[e-mail] ; [e-mail];
[e-mail].
Attorneys for Plaintiff
LEAH BULLEN
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION
LEAH BULLEN, individually, and on
behalf of other members of the general
public similarly situated,
Plaintiff,
vs.

Case No. 4:09-CV-04117 SBA (EDL)
JOINT STIPULATION AND ORDER TO
EXTEND CERTAIN DEADLINES

CITIGROUP GLOBAL MARKETS, INC.,
d/b/a SMITH BARNEY,
Defendant.

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M ORGAN , L EWIS &
B OCKIUS LLP

JOINT STIPULATION AND [PROPOSED] ORDER TO
EXTEND DEADLINES
(CASE NO.: 4:09-CV-04117 SBA (EDL))

ATTORNEYS AT LAW
PALO ALTO

DB2/ 22591162.1

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Plaintiff Leah Bullen (“Plaintiff”) and Defendant Citigroup Global Markets Inc.
(“CGMI”), by and through their attorneys of record, hereby stipulate to modify certain deadlines
set forth in this Court’s Order for Pretrial Preparation (“Order”).
WHEREAS, Plaintiff served a Federal Rule of Civil Procedure 30(b)(6) deposition notice
on June 3, 2011 for a deposition to occur June 22, 2011;
WHEREAS, on June 21, 2011, CGMI filed a Motion for Protective Order in response to
Plaintiff’s Federal Rule 30(b)(6) deposition notice;
WHEREAS, per the Order for Pretrial Preparation in this action, the discovery cut-off was
July 1, 2011;
WHEREAS, this Court held a hearing on CGMI’s Motion on August 2, 2011;
WHEREAS, at the hearing, Plaintiff’s counsel informed the Court that Plaintiff has
decided that she will no longer pursue class certification and is withdrawing the class allegations
in her Complaint;
WHEREAS, the Court granted CGMI’s Motion in part, without prejudice to Plaintiff renoticing a deposition tailored to her individual claim only, regardless of the July 1, 2011
discovery cut-off;
WHEREAS, per the Order for Pretrial Preparation, CGMI must file any dispositive
motion by August 16, 2011;
WHEREAS, Plaintiff and CGMI need additional time to schedule and complete the
deposition tailored to Plaintiff’s individual claim and likely cannot do so and receive the
transcript prior to August 16, 2011;
For the foregoing reasons, Plaintiff and CGMI hereby stipulate and respectfully request
that the following modifications be made to the Court’s Order for Pretrial Preparation:

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Previous Date

New Date

Dispositive Motion Hearing Deadline

9/20/11

11/22/11

Mandatory Settlement Conference

9/21-10/7/11

11/23-12/9/11

Pretrial Preparation

10/11/11

12/13/11

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M ORGAN , L EWIS &
B OCKIUS LLP

ATTORNEYS AT LAW

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PALO ALTO

DB2/ 22591162.1

JOINT STIPULATION AND [PROPOSED] ORDER
TO EXTEND DEADLINES
(CASE NO.: 4:09-CV-04117 SBA (EDL))

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Motions in Limine/Objections to Evidence 10/18-11/1/11

12/27-1/10/12

Pretrial Conference

11/8/11

1/17/12

Trial

11/28/11

2/6/12

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Dated: August 4, 2011

MORGAN, LEWIS & BOCKIUS LLP

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By /s/ Daryl S. Landy
Daryl S. Landy
Shweta Gera
Attorneys for Defendant
CITIGROUP GLOBAL MARKETS INC.

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Dated: August 4, 2011

INITIATIVE LEGAL GROUP, APC

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By /s/ Gene Williams
David M. Medby
Gene Williams
Sang Park
Mark Estrella
Attorneys for Plaintiff
LEAH BULLEN

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[ORDER

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IT IS SO ORDERED WITH THE FOLLOWING MODIFICATION: The dispositive

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motion hearing deadline is by November 15, 2011. Motions in limine/objections to evidence

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shall be filed by no later than December 20, 2011; oppositions to motions in limine/objections to

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evidence shall be filed by no later than December 27, 2011; and replies to motions in

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limine/objections to evidence shall be filed by no later than January 3, 2012. The parties shall

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follow this Court’s Standing Order pertaining to page limits.

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IT IS SO ORDERED.
Dated: _August 16, 2011
HON. SAUNDRA B. ARMSTRONG
UNITED STATES DISTRICT COURT JUDGE

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M ORGAN , L EWIS &
B OCKIUS LLP
ATTORNEYS AT LAW

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PALO ALTO

DB2/ 22591162.1

JOINT STIPULATION AND [PROPOSED] ORDER
TO EXTEND DEADLINES
(CASE NO.: 4:09-CV-04117 SBA (EDL))