Albertsen v. 3M Company

Filing 26

STIPULATION AND CASE MANAGEMENT SCHEDULING ORDER: Case Management Conference set for 1/19/2012 03:30 PM. VIA TELEPHONE. Signed by Judge ARMSTRONG on 11/29/11. (lrc, COURT STAFF) (Filed on 11/29/2011)

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SEYFARTH SHAW LLP
Francis J. Ortman, III (State Bar No. 213202) [e-mail]
Robb D. McFadden (State Bar No. 258569) [e-mail]
560 Mission Street, Suite 3100
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
SEYFARTH SHAW LLP
Brandon R. McKelvey (State Bar No. 217002) [e-mail]
400 Capitol Mall, Suite 2350
Sacramento, California 95814-4428
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
3M COMPANY
PATTERSON LAW GROUP, APC
Allison H. Goddard (State Bar No. 211098) [e-mail]
James R. Patterson (State Bar No. 211102) [e-mail]
402 West Broadway, Suite 2900
San Diego, California 92101
Telephone: [phone]
Facsimile: [phone]
JACZKO GODDARD LLP
J. Christopher Jaczko (State Bar No. 149317) [e-mail]
4401 Eastgate Mall
San Diego, California 92121
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
LARA ALBERTSEN

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UNITED STATES DISTRICT COURT

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IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA

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LARA ALBERTSEN,
Plaintiff,

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vs.

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3M COMPANY,
Defendant.

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Case No.: C 10-04610 SBA
STIPULATION OF PLAINTIFF LARA
ALBERTSEN AND DEFENDANT 3M
COMPANY TO CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER

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Stipulation of Plaintiff and Defendant to Continue Case
Management Conference / Case No. C 10-04610 SBA

WHEREAS, on January 5, 2011, the Court continued the Case Management Conference

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in this matter pursuant to the parties’ Stipulation to May 4, 2011 [Doc. No. 11];
WHEREAS, on January 21, 2011, Plaintiff Lara Albertsen (“Plaintiff”) filed a First

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Amended Complaint [Doc. No. 13];
WHEREAS, on February 4, 2011, Defendant 3M Company (“Defendant”) filed an

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Answer to the First Amended Complaint;
WHEREAS, the parties met and conferred in person on April 8, 2011 to discharge their

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obligations under Fed. R. Civ. P. 26 and to discuss potential settlement of this matter;

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WHEREAS, on September 21, 2011, the Court continued the Case Management

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Conference in this matter pursuant to the parties’ Stipulation to November 30, 2011 [Doc. No.

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WHEREAS, the parties participated in a mediation with Michael L. Wolfram on
September 21, 2011 in San Francisco, California;
WHEREAS, the parties agree that additional time is needed to continue discussions
exploring settlement; and,
WHEREAS, pursuant to Local Rule 16-2(e) and 7-12 the parties have stipulated to

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continue the Case Management Conference scheduled for November 30, 2011 and reschedule it

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for a date that is convenient to this Court on or after January 5, 2012.

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THEREFORE, the parties STIPULATE and agree as follows:

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(1)

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That the Case Management Conference scheduled for November 30, 2011 at 3:30

p.m. be rescheduled to a date and time convenient to this Court on or after January 5, 2012;
(2)

That all Rule 26 Meet and Confer deadlines be continued and re-calendared based

on the date of the rescheduled Case Management Conference; and
(3)

The parties may request that the new deadline for submitting a Joint Case

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Management Statement be converted to a Joint or Unopposed Motion for Preliminary Approval

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of Settlement.

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Stipulation of Plaintiff and Defendant to Continue Case
Management Conference / Case No. C 10-04610 SBA

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IT IS SO STIPULATED.

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DATED: November 28, 2011

SEYFARTH SHAW LLP

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By_________/s/______________________
Francis J. Ortman, III
Brandon R. McKelvey
Robb D. McFadden
Attorneys for Defendant
3M COMPANY

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DATED: November 28, 2011

PATTERSON LAW GROUP APC

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BY_________/s/_____________________
James R. Patterson
Attorneys for Plaintiff
LARA ALBERTSEN

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Stipulation of Plaintiff and Defendant to Continue Case
Management Conference / Case No. C 10-04610 SBA

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ORDER

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PURSUANT TO THE STIPULATION OF THE PARTIES, and finding good cause

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therein, IT IS HEREBY ORDERED that the:
Case Management Conference scheduled for November 30, 2011 at 3:30 p.m. is

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continued to January 19, 2012 at 3:30 p.m. All Rule 26 Meet and Confer deadlines are

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continued and re-calendared based on the date of the rescheduled Case Management Conference.

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Absent unforeseen exigent circumstances, no further continuances of the Case

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Management Conference will be granted.

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Plaintiff’s counsel is to set up the conference call with all the parties on the line and call

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chambers at [phone]. (No party shall contact chambers directly without prior

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authorization of the Court.)

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Plaintiff(s) is directed to serve a copy of this Order at once on all parties to this action in

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accordance with the provisions of Rule 5 of the Federal Rules of Civil Procedure not enrolled in

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the e-filing program. Following service, the party causing the service shall file a certificate of

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service with the Clerk of Court.

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IT IS SO ORDERED.

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DATED: 11-29-11

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_______________________________________
HON. SAUNDRA BROWN ARMSTRONG
UNITED STATED DISTRICT COURT JUDGE

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13979537v.2 / 59096-000005

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Stipulation of Plaintiff and Defendant to Continue Case
Management Conference / Case No. C 10-04610 SBA