Ho v. Ernst & Young LLP

Filing 268

STIPULATION AND ORDER CONTINUING DEADLINE FOR FILING DEFENDANT'S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION, AND FOR PLANITIFFS' REPLY IN SUPPORT OF THEIR MOTION. Signed by Judge Jeremy Fogel on 9/27/2010. (jflc2, COURT STAFF) (Filed on 9/27/2010)

pp~

CATHERINE A. CONWAY (SBN 98366) GREGORY W. KNOPP (SBN 237615) CHRISTOPHER K. PETERSEN (SBN 260631)

AKIN GUMP STRAUSS HAUER & FELD LLP 2029 Century Park East, Suite 2400 Los Angeles, California 90067-3012
Telephone: [phone] Facsimile: 310-229- 1001

**E-Filed 9/27/2010**

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Attorneys for Defendant, ERNST & YOUNG LLP
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
DAVID HO, on behalf of himself and others similarly situated and on behalf of the
general public and DOES 1-

Case No. CV 05-04867 JF (HRL)

Plaintiff

ERNST & YOUNG, LLP
Defendant.

----------------STIPULATION AND -(PROPOSED)-ORDER CONTINUING DEADLINE FOR FILING DEFENDANT' S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION , AND FOR PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION
C 08-2853 JF (HRL)

JOSEPH LANDON individually and on behalf of all others similarly situated

Plaintiff

ERNST & YOUNG LLP, a limited liability partnership; ERNST & YOUNG U. S. LLP, a limited liability partnership; and DOES I100 , inclusive
Defendant.

Caption continued on next page.

STIPULATION AND (PROPOSED) ORDER CONTINUING DEADLINE FOR FILING DEFENDANT'S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION , AND FOR PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION CV 05-04867 IF

MICHELLE RICHARDS , on behalf 16 of herself and all others similarly situated and on behalf of the general public

C 08-4988 JF (HRL)

Plaintiff

ERNST & YOUNG LLP, and DOES - 50
Defendant.

STIPULATION AND (PROPOSED) ORDER CONTINUING DEADLINE FOR FILING DEFENDANT'S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION , AND FOR PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION CV 05-04867

IF

Plaintiffs Sarah Fernandez and Michelle Richards, and Defendant Ernst & Young LLP, by and

through their respective counsel, hereby agree and stipulate as follows:

WHEREAS pursuant to the parties ' stipulation which the Court approved on July 2 2010
Defendant' s opposition to Plaintiffs ' motion for class certification would be due October 22 2010 , and

Plaintiffs ' reply in support of their motion would be due November 22 2010;

WHEREAS the parties are working together to schedule Defendant's depositions of putative
class members who submitted declarations in support of Plaintiffs ' motion for class certification;
WHEREAS,

the parties are also working to schedule Defendant's deposition of Plaintiffs

expert witness, Roger B. Shlonsky, who is out of the country through November;

WHEREAS the parties have met and conferred and agree that in order to accommodate these
depositions , the briefing schedule should be amended as follows:
1. Defendant' s

opposition to Plaintiffs ' motion for class certification is due on or before
2010; and

December 31 ,
2. Plaintiffs '

reply in support of their motion for class certification is due on or before March

2011.

Respectfully submitted
Dated: September 24

2010

AKIN GUMP STRAUSS HAUER & FELD LLP

Isl Gregory W Knopp
Gregory W. Knopp Attorneys for Defendant ERNST & YOUNG LLP
Dated: September 24 , 2010

HOFFMAN & LAZEAR
By

Libenson Ross L. Libenson Attorneys for Plaintiffs David Ho, Sarah Fernandez and Michelle Richards
Isl Ross L.

PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated:

September 27

2010

The Honorable Jeremy Fogel JUDGE , UNITED STATES DISTRICT COURT

STIPULATION AND (PROPOSED) ORDER CONTINUING DEADLINE FOR FILING DEFENDANT'S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION , AND FOR PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION CV 05-04867

IF

PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 2029 Century Park East , Suite 2400, Los Angeles , California 90067. On September 24 2010 , I served the foregoing document(s) described as: STIPULATION AND (PROPOSED) ORDER CONTINUING DEADLINE FOR FILING DEFENDANT' S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION, AND FOR PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION on the interested party(ies) below, using the following means:

All parties identified for Notice of Electronic Filing generated by the Court' s CMlECF system under the referenced case
caption and number

~ BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION. Based on a court order or an agreement of the parties to accept service bye-mail or electronic transmission, I caused the document(s) to be sent to the respective e-mail addressees) of the party(ies) as stated above. I did not receive , within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful.
I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.
Executed on September 24, 2010 at Los Angeles, California.

Dawnmarie Kucko
IPrint Name of Person Executing Proof)

STIPULATION AND (PROPOSED) ORDER CONTINUING DEADLINE FOR FILING DEFENDANT'S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION , AND FOR PLAINTIFFS' REPLY IN SUPPORT OF THEIR MOTION CV 05-04867 IF