Seebrook v. The Children's Place Retail Stores, Inc.

Filing 40

ORDER Granting 39 Stipulation to Extend Deadlines re Class Certification. Case Management Statement due by 8/2/2012. Further Case Management Conference set for 8/9/2012 02:00 PM. Motions due by 6/7/2012. Responses due by 7/12/2012. Replies due by 7/26/2012. Motion Hearing set for 8/9/2012 02:00 PM before Hon. Claudia Wilken. Signed by Judge Claudia Wilken on 12/2/2011. (ndr, COURT STAFF) (Filed on 12/2/2011)

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COOLEY LLP
MICHELLE C. DOOLIN (179445) ([e-mail])
MAZDA K. ANTIA (214963) ([e-mail])
JENNIFER M. FRENCH (265422) ([e-mail])
4401 Eastgate Mall
San Diego, CA 92121
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant
THE CHILDREN’S PLACE RETAIL STORES, INC.

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(See Signature Page for complete list of parties represented.)

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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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GALINA SEEBROOK, individually and on
behalf of all others similarly situated,

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Plaintiffs,
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Consolidated Case No. 11-cv-00837-CW
STIPULATION AND [PROPOSED] ORDER TO
EXTEND DEADLINES RE CLASS
CERTIFICATION

v.
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THE CHILDREN’S PLACE RETAIL
STORES, INC., a Delaware corporation,

Judge:
Place:

Hon. Claudia Wilken
Courtroom 2, 4th Floor

Trial Dates: Not Yet Set
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Defendant.

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MARIA ISABEL BELTRAN, an individual,
on behalf herself and of all others similarly
situated,

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Plaintiff,

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Case No. 11-cv-01664-CW

v.
THE CHILDREN’S PLACE RETAIL
STORES, INC., a Delaware Corporation; and
DOES 1 through 50, inclusive,
Defendants.

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CONSOLIDATED CASE NO. 11-CV-00837-CW

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE CLASS CERTIFICATION

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NICOLLE DiSIMONE, individually, and on
behalf of all others similarly situated,

Case No. 11-cv-02223-CW

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Plaintiff,
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v.
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THE CHILDREN’S PLACE RETAIL
STORES, INC., a Delaware corporation, and
DOES 1 – 500,

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Defendants.
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KRISTEN HARTMAN, an individual, on
behalf of herself and all others similarly
situated,

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Plaintiffs,

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Case No. 11-cv-02604-CW

v.
THE CHILDREN’S PLACE RETAIL
STORES, INC., a Delaware Corporation, and
DOES 1 through 50, inclusive

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Defendants.

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Plaintiffs Galina Seebrook, Maria Isabel Beltran, Nicolle DiSimone, and Kristen

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Hartman and defendant The Children’s Place Retail Stores, Inc. (“Children’s Place”), by and

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through their respective counsel, jointly submit the following stipulation to extend the deadlines

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regarding class certification.

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RECITALS

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WHEREAS, the parties have scheduled a mediation before Judge Edward A. Infante
(Ret.) on February 27, 2010; and

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WHEREAS, the parties believe that an extension of the deadlines regarding class

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certification is warranted for judicial efficiency and to allow the parties to focus their efforts and

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resources on settlement efforts;

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///

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///

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

1.

CONSOLIDATED CASE NO. 11-CV-00837-CW

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE CLASS CERTIFICATION

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STIPULATION
NOW, THEREFORE, IT IS STIPULATED

AND

AGREED, by the parties, through their

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respective counsel of record, that the dates relating to class certification shall be extended as

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follows:

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

Parties to exchange class expert disclosures and reports for affirmative
experts on or before April 6, 2012.



Parties to exchange class expert disclosures and reports for rebuttal experts
on or before May 4, 2012.



Plaintiffs shall file any motion for class certification on or before June 7,
2012.



Children’s Place shall file any opposition to class certification on or before
July 12, 2012.



Plaintiffs shall file any reply brief in support of class certification on or
before July 26, 2012.



Hearing on class certification shall be held on August 9, 2012 at 2:00 PM or
at the Court’s convenience.

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IT IS SO STIPULATED.

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Dated: December 1, 2011

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COOLEY LLP
MICHELLE C. DOOLIN (179445)
MAZDA K. ANTIA (214963)
JENNIFER M. FRENCH (265422)

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/s/ Jennifer M. French
Jennifer M. French
Attorneys for Defendant
THE CHILDREN’S PLACE RETAIL STORES, INC.

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

2.

CONSOLIDATED CASE NO. 11-CV-00837-CW

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE CLASS CERTIFICATION

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Dated: December 1, 2011

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HOFFMAN & LAZEAR
H. TIM HOFFMAN (049141)
ARTHUR W. LAZEAR (083603)
CHAD A. SAUNDERS (257810)

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/s/ Chad A. Saunders
Chad A. Saunders

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Attorneys for Plaintiff
GALINA SEEBROOK

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Dated: December 1, 2011

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PATTERSON LAW GROUP, APC
JAMES R. PATTERSON (211102)
MATTHEW J. O’CONNOR (203334)

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/s/ James R. Patterson
James R. Patterson

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Attorneys for Plaintiff
MARIA ISABEL BELTRAN

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Dated: December 1, 2011

RIDOUT & LYON, LLP
CHRISTOPHER P. RIDOUT (143931)
DEVON M. LYON (218293)
CALEB LH MARKER (269721)
QUALLS & WORKMAN, LLP
DANIEL H. QUALLS (109036)
ROBIN G. WORKMAN (145810)
AVIVA N. ROLLER (245415)

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/s/ Christopher P. Ridout
Christopher P. Ridout
Attorneys for Plaintiff
NICOLLE DiSIMONE

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

3.

CONSOLIDATED CASE NO. 11-CV-00837-CW

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE CLASS CERTIFICATION

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Dated: December 1, 2011

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STONEBARGER LAW, APC
GENE J. STONEBARGER (209461)
RICHARD D. LAMBERT (251148)

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/s/ Gene J. Stonebarger
Gene J. Stonebarger

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Attorneys for Plaintiff
KRISTEN HARTMAN

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FILER’S ATTESTATION

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Filer’s Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures,

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Jennifer M. French hereby attests that concurrence in the filing of this document has been

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obtained.

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

4.

CONSOLIDATED CASE NO. 11-CV-00837-CW

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE CLASS CERTIFICATION

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[PROPOSED] ORDER
Based on the foregoing, and good cause appearing, IT IS HEREBY ORDERED that the
dates relating to class certification shall be extended as follows:


Parties to exchange class expert disclosures and reports for affirmative
experts on or before April 6, 2012.



Parties to exchange class expert disclosures and reports for rebuttal experts
on or before May 4, 2012.



Plaintiffs shall file any motion for class certification on or before June 7,
2012.



Children’s Place shall file any opposition to class certification on or before
July 12, 2012.



Plaintiffs shall file any reply brief in support of class certification on or
before July 26, 2012.



Hearing on class certification shall be held on August 9, 2012 at 2:00 PM.

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IT IS SO ORDERED. A further Case management conference will also be held on August 9, 2012.

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Dated: 12/2/2011

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_______________________________________
THE HONORABLE CLAUDIA WILKEN
UNITED STATES DISTRICT JUDGE

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COOLEY LLP
ATTORNEYS AT LAW
SAN DIEGO

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CONSOLIDATED CASE NO. 11-CV-00837-CW

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES RE CLASS CERTIFICATION