Laurie Munning v. The Gap, Inc. et al

Filing 92

ORDER by Judge Haywood S. Gilliam, Jr. Granting 91 Stipulation to Continue Case Management Deadlines. Close of Fact Discovery due by 6/29/2018; Designation of Experts due by 7/27/2018; Designation of Rebuttal Experts due by 8/24/2018; Close of Expert Discovery due by 9/7/2018; Motions due by 10/5/2018; Motion Hearing set for 12/6/2018 02:00 PM before Judge Haywood S. Gilliam Jr. (ndrS, COURT STAFF) (Filed on 2/1/2018)

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LAW OFFICES OF TODD M. FRIEDMAN
Todd M. Friedman, Bar No. 216752
[e-mail]
324 South Beverly Drive, #725
Beverly Hills, CA 90212
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff
LAURIE MUNNING

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MORGAN, LEWIS & BOCKIUS LLP
Joseph Duffy, Bar No. 241854
[e-mail]
Esther K. Ro, Bar No. 252203
[e-mail]
300 South Grand Avenue
Twenty-Second Floor
Los Angeles, CA 90071-3132
Tel: [phone]
Fax: [phone]
Attorneys for Defendants
THE GAP, INC., GAP (APPAREL) LLC, GAP
INTERNATIONAL SALES, INC., BANANA
REPUBLIC LLC, and BANANA REPUBLIC
(APPAREL) LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LAURIE MUNNING, on behalf of herself and
all others similarly situated,

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Plaintiff,

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Case No. 4:16-cv-03804-HSG
JOINT STIPULATION TO CONTINUE
CASE MANAGEMENT DEADLINES
AND ORDER

vs.
THE GAP, INC., GAP (APPAREL) LLC, GAP
INTERNATIONAL SALES, INC., BANANA
REPUBLIC LLC, and BANANA REPUBLIC
(APPAREL) LLC,

Hearing Date:
Hearing Time:
Judge:

N/A
N/A

Hon. Haywood S. Gilliam, Jr.

Defendants.

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MORGAN, LEWIS &
BOCKIUS LLP

Joint Stipulation and Order

ATTORNEYS AT LAW
LOS ANGELES

DB2/ 32692259.2

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The parties jointly stipulate to continue the case management deadlines currently set in

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this case in order to coordinate discovery with the related case, Pallagrosi v. Gap, Inc. et al., Case

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No. 4:17-cv-05905-HSG. On January 23, 2018, counsel for Plaintiff and the Gap Defendants

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appeared before this Court for the Initial Case Management Conference in Pallagrosi. At the

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conference, counsel proposed a new case management schedule so that the schedule in this case

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would coordinate with discovery in Pallagrosi. While Munning and Pallagrosi are on behalf of

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two different classes of purchasers, both cases involve the Gap Defendants’ alleged sales

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practices in the marketing of its merchandise. The parties filed a proposed scheduling order in

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Pallagrosi on January 30, 2018. See Pallagrosi Dkt. 30. As the parties explained at the

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conference, many of the documents produced in the two cases by both parties will overlap. In

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addition, the majority of witnesses to be deposed probably will overlap as well. For this reason,

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the parties proposed to this Court the intention to have the two cases be coordinated so discovery

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may track consistently. This will permit the parties to be more efficient and cost effective in the

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two cases.

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The parties propose the same schedule as requested in Pallagrosi:

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

Fact discovery cutoff

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o The parties propose that all fact discovery will be completed by June 29, 2018.


Expert disclosures

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o The parties shall provide initial expert disclosures on July 27, 2018 and

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rebuttal expert disclosures on August 24, 2018. Expert discovery shall be

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completed by September 7, 2018, including expert depositions.

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

L/D to file motion to class certification

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o Plaintiff shall move for class certification in Munning on or before October 5,

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2018. Defendants shall have 30 days to file their brief in opposition to class

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certification and Plaintiff shall have 15 days to file her reply brief in support of

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class certification. The Class Certification hearing shall be on or after

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December 6, 2018.

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MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
LOS ANGELES

DB2/ 32692259.2

Joint Stipulation and Order

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o Plaintiffs shall move for class certification in Pallagrosi on or before

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December 28, 2018. Defendants shall have 30 days to file their brief in

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opposition to class certification and Plaintiff shall have 15 days to file her reply

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brief in support of class certification. The Class Certification hearing shall be

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on or after February 28, 2019.

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SO STIPULATED.

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Dated: January 31, 2018

LAW OFFICES OF TODD M. FRIEDMAN

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By /s/ Todd M. Friedman
Todd M. Friedman

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and

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DeNITTIS OSEFCHEN, P.C.
Stephen P. DeNittis, Esq. (admitted pro hac vice)
Ross H. Schmierer, Esq. (admitted pro hac vice)

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Attorneys for Plaintiff
LAURIE MUNNING

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Dated: January 31, 2018

MORGAN, LEWIS & BOCKIUS LLP

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By /s/ Joseph Duffy
Joseph Duffy
Esther K. Ro
Attorneys for Defendants
THE GAP, INC., GAP (APPAREL) LLC, GAP
INTERNATIONAL SALES, INC., BANANA
REPUBLIC LLC, and BANANA REPUBLIC
(APPAREL) LLC

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MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
LOS ANGELES

DB2/ 32692259.2

Joint Stipulation and Order

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ATTEST
TATION
I, Josep Duffy, am the registe
ph
m
ered ECF use whose use
er
ername and password ar being used
re
d

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to file this Join Stipulation. In compl
nt
liance with L 5-1(i)(3), I hereby att that the aboveLR
,
test

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ide
entified coun concurr in this fil
nsel
red
ling.

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Da
ated: Januar 31, 2018
ry

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By /s/ J
Joseph Duff
ffy

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PURSUANT TO STIPULAT
TION, AND FOR GOO CAUSE SHOWN, I IS SO
D
OD
IT
OR
RDERED.

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Da
ated: Februa 1, 2018
ary

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____
___________
__________
___________
________
HON
NORABLE H
HAYWOOD S. GILLIA JR.
D
AM,
Unite States District Judge
ed

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MORGAN, LEWIS &
BOCKIUS LLP
S

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ATTORNEYS AT LAW
LOS ANG
GELES

DB2/ 32692259.2
/

Joi Stipulatio and Order
int
on