Blennis et al v. Helett-Packard Company

Filing 35

ORDER GRANTING STIPULATED REQUEST TO CONTINUE ADR SESSION re 34 Stipulation filed by Hewlett-Packard Company. Signed by Judge Jeremy Fogel on 2/7/08. (jfsec, COURT STAFF) (Filed on 2/8/2008)

Blennis et al v. Hewlett-Packard Company

Doc. 35

1 PETER SULLIVAN, SBN 101428

PSullivaii~gibsondunn.com

2 SAML G. LIVERSIDGE, SBN 180578
SLiversidge~gibsondunn.com
3 MICHAEL H. DORE, SBN 227442

MDore~gibsondunn.com 4 GIBSON, DUN & CRUTCHER LLP
333 South Grand Avenue
5 Los Angeles, California 90071-3197

Telephone: [phone]
6 Facsimile: [phone]

**E-filed 2/8/08**

7 Attorneys for Defendant

HEWLETT -PACKA COMPAN
8

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UNTED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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JACKI BLENNIS and DAVID BRICKNR,
14 individually and on behalf of all others similarly situated,
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CASE NO. C 07 00333-JF

Plaintiffs,
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v.

---------------JOINT STIPULATION AND (PROPOSED) ORDER CONTINUING DEADLINE TO HOLD ADR SESSION; SUPPORTING

DECLARTIONS OF ALFREDO
TORRJOS AND MICHAEL H. DORE
(N.D. CaL. Local Rule 6-1(b) & 6-2)

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HEWLETT-PACKA COMPAN, a
18 Californa Corporation; and DOES 1 through

250, inclusive,
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. Defendants.

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Gibson, Dunn & Crutcher LLP

JOINT STIPULATION AND (PROPOSED) ORDER CONTINUIG DEADLINE TO HOLD ADR SESSION

Case No. C 0700333 JF
Dockets.Justia.com

1 JOINT STIPULATION
2 WHREAS Plaintiffs Jackie Blennis and David Brickner ("Plaintiffs") commenced this
3 action by filing a Complaint on Januar 17, 2007, and serving the Complaint on Defendant Hewlett-

4 Packard Company ("Defendant") on May 1, 2007;

5 WHEREAS on August 20, 2007, the Court (Judge Ronald Whyte presiding) set the deadline
6 for the paries to hold an ADR session at 180 days from the date of

his August 20, 2007 order, that is,

7 February 16, 2008;

8 WHREAS on Januar 14, 2008, the Cour granted the parties' stipulated request to continue
9 the case management conference in this matter until March 14, 2008 at 10:30 a.m.; and
10 WHEREAS good cause exists for approving this Joint Stipulation in light of

the procedural

11 postue of

this and related cases pending in this Court in which HP is a defendant.

12 ACCORDINGLY, pursuant to Local Rule 6-1(b), the pares, by and through their counsel of
13 record, hereby stipulate to, and request the Cour's approval ofthe following:
14 . The pares agree that the existing deadline for the paries to hold the ADR session shall

15 be moved from February 16,2008, to May 16, 2008.
16 IT

IS SO STIPULATED.

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18 DATED: Februar 2.,2008
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KAATECK BROWN KELLNER LLP
BRIAN S. KABA TECK

RICHAR L. KELLNER
ALFREDO TORRIJOS

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B

Alfredo Torrjos

~-.
/
Case No. C 0700333 JF

Attorneys for Plam 1 fs JACKIE BLENNIS and DAVID

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BRICKNR

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Gibson, Dunn &
Crutcher LLP

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JOINT STIPULATION AND (PROPOSED) ORDER CONTINUIG DEADLINE TO HOLD ADR SESSION

1

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DATED: February!4, 2008

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GIBSON, DUN & CRUTCHER LLP
PETER SULLIV AN

SAML G. LIVERSIDGE
MICHAEL H. DORE

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L- t6

By:
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7£ 'i

Michael H. //

Attorneys for Defendant HEWLETT -P ACKA

COMPAN

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10 PURSUANT TO STIPULATION, IT IS SO ORDERED.
11 Dated:
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2/7/08

,2008

14 United States Distrct Judge
The Hon. Jeremy Fogel
15 1 00382052J

DOC

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Gibson, Dunn & Crutcher LLP

JOINT STIPULATION AND (PROPOSED) ORDER CONTINUING DEADLINE TO HOLD ADR SESSION

Case No. C 0700333 JF

1

DECLARTION OF MICHAEL H. DORE
I, Michael H. Dore, declare as follows:
1.
I am an attorney admitted to practice law before all courts of the State of

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California

4 and I intend to submit an application to become a member of

the bar of

this Court. I am an associate

5 in the law firm of

Gibson, Dunn & Crutcher LLP, and I am one of

the attorneys responsible for the

6 representation of

Defendant Hewlett-Packard Company ("HP") in the action entitled Jackie Blennis

7 and David Brickner, et at. v. Hewlett-Packard Company, et at. (N.D. CaL. Case No. C 07-003338 RMW). Pursuant to Local Rule 6-2(a), I submit this declaration in support of

the paries' Joint

9 Stipulation and (Proposed) Order Continuing Deadline to Hold ADR Session (the "Joint

10 Stipulation"). Unless otherwise stated, the following facts are within my personal knowledge and, if
11 called and sworn as a witness, I could and would testify competently thereto.
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2.

The Reasons for the Requested Enlargement or Shortening of Time (Local Rule 6the procedural posture of

13 2(a)(1)). I believe that in light of

this case and related cases pending in this

14 Cour in which HP is a defendant, effciency would best be served by extending the deadline for the
15 parties to hold their ADR session.
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3.

Prior Time Modifications in this Case (Local Rule 6-2(a)(2)). The parties twice have
the case management conference be continued while HP's motion to

17 requested that the date of

18 dismiss was pending. Those requests have been granted. The case management conference now is

19 scheduled for March 14, 2008.

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4.

Effect ofthe Requested Time Modification on the Schedule for the Case (Local

Rule 6-2(a)(3)). The requested extension oftime to hold an ADR session would change the deadline
from February 16,2008 until May 16, 2008.
I declare under penalty of peijury that the foregoing is tre and correct.

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DATED: FebruaryL,2008

L_~ ~__
MICHAL . DORE

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Gibson, Dunn & Crutcher LLP

100382052_1 DOC

DECLARTION OF MICHAEL H. DORE

Case No. C 0700333 JF

1

DECLARTION OF ALFREDO TORRJOS
I, Alfredo Torrjos, declare as follows:
1. I am an attorney admitted to practice law before all cours of

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the State ofCalifomia. 1 am
the attorneys

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an associate in the law firm of

Kabateck Brown Kellner LLP, and I am one of

responsible for the representation of

Plaintiffs Jackie Blennis and David Brickner ("Plaintiffs") in the

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action entitled Jackie Blennis and David Brickner, et al. v. Hewlett-Packard Company, et al. (N.D.
CaL. Case No. C 07-00333-RMW). Pursuant to Local Rule 6-2(a), I submit this declaration in
support of

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the paries' Joint Stipulation and (Proposed) Order Continuing Deadline to Hold ADR

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Session (the "Joint Stipulation"). Unless otherwse stated, the following facts are within my personal
knowledge and, if called and sworn as a witness, I could and would testify competently thereto_
2. The Reasons for the Requested Enlargement or Shortenin.g 6fTime (Local Rule 62(a)(I)). I believe that in light of the procedural posture of

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this case and related cases pending in this

Cour in which HP is a defendant, efficiency would best be served by extending the deadline for the

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paries to hold their ADR session.

3. Prior Time Modifications in this Case (Local Rule 6-2(a)(2)). The parties twice have
requested that the date of

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the case management conference be continued while HP's motion to

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dismiss was pending. Those requests have been granted. The case management conference now Is
scheduled for March 14, 2008.
4. Effect of

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the Requested Time Modification on the Schedule for the Case (Local Rule 6-

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2(a)(3)). The requested extension oftime to hold an ADR session would change the deadline from
February 16, 2008 until May 16,2008.
I declare under penalty of

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perjury that the foregoing is tre and correct.

DATED: February 1,2008

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~TO:r
DECLARTION OF ALFREDO TORRJOS
Case No. C 07 00333 JF

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Gibson, Dunn & Crutcher LLP