Gil et al v. Solectron Corporation et al

Filing 153

STIPULATION AND ORDER 113 Abating Pretrial Deadlines and Setting Case Management Conference. Case Management Conference set for 7/10/2009 10:30 AM. Signed by Judge Ronald M. Whyte on 4/30/09. (jg, COURT STAFF) (Filed on 4/30/2009) (Additional attachment(s) added on 4/30/2009: # 1 CORRECT ORDER) (jg, COURT STAFF).

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Counsel Appear on the Following Page

*E-FILED - 4/30/09*

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION Mohan Gil, et al, on behalf of others similarly situated, and on behalf of the general public, Plaintiffs, v. Solectron Corporation, et al, Defendants. Case No. C 07-06414 RMW (HRL) JOINT STIPULATION AND [] ORDER ABATING PRETRIAL DEADLINES AND SETTING CASE MANAGEMENT CONFERENCE Honorable Ronald M. Whyte Complaint Filed: December 19, 2007

STIPULATION AND ] ORDER

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

NICHOLS KASTER, LLP Matthew C. Helland, CA State Bar No. 250451 [e-mail] One Embarcadero Center, Suite 720 San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] NICHOLS KASTER, PLLP James H. Kaster, CA State Bar No. 248949 [e-mail] 4600 IDS Center, 80 South 8th Street Minneapolis, MN 55402 Telephone: [phone] Facsimile: [phone] Attorneys for INDIVIDUAL AND REPRESENTATIVE PLAINTIFFS JOAN B. TUCKER FIFE (SBN:144572) email: [e-mail] WINSTON & STRAWN LLP 101 California Street, Suite 300 San Francisco, CA 94111 Telephone: [phone] Facsimile: 415-591-1400 JENNIFER RAPPOPORT (SBN: 210879) email: [e-mail] WINSTON & STRAWN LLP 333 South Grand Avenue Los Angeles, CA 90071-1543 Telephone: [phone] Facsimile: 213-615-1750 Attorneys for DEFENDANTS SOLECTRON CORPORATION, FLEXTRONICS INTERNATIONAL, USA, INC., and AEROTEK, INC.

-2STIPULATION AND [] ORDER

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and

Plaintiffs MOHAN GIL, RODNEY CARR, TONY DANIEL, and JERMAINE WRIGHT, individually, on behalf of others similarly situated, and on behalf of the general public ("Plaintiffs") and Defendants SOLECTRON CORPORATION, FLEXTRONICS

INTERNATIONAL, USA, INC., and AEROTEK, INC. (referred to herein collectively as "Defendants"), hereby stipulate and agree as follows:

WHEREAS, on July 16, 2008, the Court adopted the parties' stipulation regarding Plaintiffs' First Amended Complaint, which included a request for a Case Management Conference to discuss the current pretrial schedule; and WHEREAS, the Court has not set a Case Management Conference to discuss the current pretrial schedule; and WHEREAS, the Court granted Plaintiffs' motion for conditional class certification on January 9, 2009; and WHEREAS, Defendants recently selected new counsel to represent them in this matter;

WHEREAS, Defendants produced a class list to Plaintiffs on Friday, March 27, 2009; and WHEREAS, the class list includes approximately 17,500 employees; and WHEREAS, because of the size of the list, Plaintiffs expect they will be able to distribute notice within the next two weeks; and WHEREAS, the parties anticipate an opt-in period that will extend into July 2009; and WHEREAS, the current pretrial schedule includes a deadline of April 1, 2009 for expert disclosures, a deadline of May 1, 2009 for Plaintiffs to file their Rule 23 Class Certification motion, and a deadline of June 1, 2009 for the close of discovery; and WHEREAS, there have been no previous modifications of the discovery deadlines or trial date in this matter; NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED that: 1) The parties jointly request that the deadlines in the current pretrial schedule,

docket number 48, shall be abated. -3STIPULATION AND [] ORDER

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

2) 10:30 a.m. 3)

The parties jointly request a case management conference on July 10, 2009, at

The parties agree to submit a proposed case management order by June 26, 2009.

Dated: March 31, 2009 By:

NICHOLS KASTER, LLP s/ Matthew C. Helland Matthew C. Helland ATTORNEYS FOR PLAINTIFFS AND THE PUTATIVE CLASSES

Dated: March 31, 2009 By:

WINSTON & STRAWN LLP s/ Jennifer Rappoport Joan B. Tucker Fife Jennifer Rappoport Attorneys for DEFENDANTS SOLECTRON CORPORATION, FLEXTRONICS INTERNATIONAL, USA, INC., and AEROTEK, INC. ORDER

Having read the foregoing Stipulation of the parties, and good cause appearing therefore, IT IS SO ORDERED. Dated: 4/30/09 Hon. Ronald M. Whyte United States District Court Judge

-4STIPULATION AND [] ORDER