Gehl et al v. Bloomin' Brands et al

Filing 92

STIPULATION AND ORDER re 90 STIPULATION WITH PROPOSED ORDER AND REQUEST TO CONTINUE MARCH 31, 2015 CASE MANAGEMENT CONFERENCE filed by Sara Ewart, Chris Armenta, Ryan Tyson, T-Bird Nevada, LLC, Shannon Spalding, Ramon Perez, Tr ent Broadstreet, Alex Burroughs, Holly Gehl, Jamie Metter, T-Bird Restaurant Group, Inc., Brittni Zacher Case Management Conference set for 4/28/2015 01:30 PM. Signed by Magistrate Judge Kandis A. Westmore on 3/24/15. (sisS, COURT STAFF) (Filed on 3/24/2015)

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1 DON SPRINGMEYER dspringmeyer@wrslawyers.com 2 BRADLEY S. SCHRAGER (Admitted Pro Hac Vice) bschrager@wrslawyers.com 3 JUSTIN JONES (SBN 218217) jjones@wrslawyers.com 4 WOLF, RIFKIN, SHAPIRO, SCHULMAN & RABKIN, LLP 3556 E. Russell Road, Second Floor 5 Las Vegas, Nevada 89120 Telephone: (702) 341-5200 6 Facsimile: (702) 341-5300 7 MATTHEW OSTER (SBN 190541) moster@wrslawyers.com 8 ERIC LEVINRAD (SBN 169025) elevinrad@wrslawyers.com 9 JOSHUA A. SHAPIRO (SBN 229741) jshapiro@wrslawyers.com 10 RICARDO ROZEN (SBN 279151) rrozen@wrslawyers.com 11 WOLF, RIFKIN, SHAPIRO, SCHULMAN & RABKIN, LLP th 11400 West Olympic Boulevard, 9 Floor 12 Los Angeles, California 90064-1582 Telephone: (310) 478-4100/Fax: (310) 479-1422 13 Attorneys for Plaintiffs 14 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION 17 18 HOLLY GEHL; CHRIS ARMENTA; et al. each on behalf of himself/herself, 19 and on behalf of all others similarly situated, 20 Plaintiffs, 21 vs. 22 T-BIRD RESTAURANT GROUP, 23 INC., a California corporation; T-BIRD NEVADA, LLC, a Nevada Limited Case No. 4:13-cv-05961-KAW [Judge Kandis A. Westmore] JOINT STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE PRESENTLY SCHEDULED FOR MARCH 31, 2015; [PROPOSED] ORDER 24 Liability Company; and DOES 1 through 100, Inclusive, DEMAND FOR JURY TRIAL 25 Defendants. 26 Trial Date: None 27 28 4:13-cv-05961-KAW JOINT STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE 1 The parties to the above-captioned action, through their attorneys of record, 2 hereby stipulate and agree as follows: 3 WHEREAS, a Case Management Conference in this matter is currently 4 scheduled for March 31, 2015 at 1:30 P.M.; 5 WHEREAS, the Court scheduled the March 31, 2015 Case Management 6 Conference for a week after the completion of briefing on the Motion for Class 7 Action Certification, which, at the time, was scheduled to be completed on March 8 25, 2015; 9 WHEREAS, the briefing schedule on the Motion for Class Certification was 10 subsequently extended pursuant to the stipulation of the Parties [DKT # 79] and 11 Order of the Court [DKT # 80], with the result that Plaintiffs’ reply in support of 12 their motion for class certification is presently due on or before April 8, 2015; 13 WHEREAS, on March 20, 2015, the parties’ filed a Joint Motion and 14 Proposed Order requesting leave for Defendants and Plaintiffs to file opposition and 15 reply briefs in connection with the pending Motion for Class Certification that are 16 five pages longer than otherwise permitted by the local rules, and for the date by 17 which Plaintiffs are required to file their reply in support of such motion to be 18 extended to April 13, 2015 [DKT # 89]; and 19 WHEREAS, in light of the extension of the briefing period on the Motion for 20 Class Certification (which may be further extended pursuant to the Parties’ recently 21 filed Joint Motion), the Parties respectfully stipulate and request that the Case 22 Management Conference be continued from its current date of March 31, 2015, to a 23 new date on or after April 20, 2015 (i.e. at least a week after the completion of 24 briefing on Plaintiffs’ Motion for Class Certification). 25 / / / 26 / / / 27 / / / 28 / / / 1892773.1 4:13-cv-05961-KAW -2JOINT STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE 1 THEREFORE, IN LIGHT OF THE FOREGOING, THE PARTIES HEREBY 2 STIPULATE, AGREE; AND JOINTLY REQUEST: 3 That the Case Management Conference be continued from March 31, 2015 to 4 a date on or after April 20, 2015 (at least a week after the completion of briefing on 5 Plaintiffs’ Motion for Class Certification). 6 IT IS SO STIPULATED. 7 8 9 DATED: March 24, 2015 WOLF, RIFKIN, SHAPIRO, SCHULMAN & RABKIN, LLP 10 11 By: /s/ Eric Levinrad ERIC LEVINRAD Attorneys for Plaintiffs 12 13 14 15 DATED: March 24, 2015 LATHROP & GAGE, LLP 16 17 By: /s/ Beth Schroeder BETH SCHROEDER LAUREN KATUNICH ALLISON WALLIN (Admitted Pro Hac Vice) Attorneys for T-BIRD RESTAURANT GROUP, INC. and T-BIRD NEVADA, LLC 18 19 20 21 22 23 24 25 26 27 28 1892773.1 4:13-cv-05961-KAW -3JOINT STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE 1 [PROPOSED] ORDER 2 In light of the stipulation by and between Plaintiffs and the T-Bird 3 Defendants, and for good cause shown, IT IS HEREBY ORDERED THAT the Case 4 Management Conference in this matter is hereby continued from its current date of 5 March 31, 2015 to _______________, 2015 at 1:30 p.m. April 28 6 7 DATED: 3/24/15 8 9 HON. KANDIS A. WESTMORE UNITED STATES MAGISTRATE JUDGE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1892773.1 4:13-cv-05961-KAW -4JOINT STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE

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