Lopez v. Wal-Mart Stores, Inc

Filing 75

Order by Hon. Lucy H. Koh granting 74 Stipulation.(lhklc3, COURT STAFF) (Filed on 4/26/2012)

Case5:11-cv-01632-LHK Document74 Filed04/26/12 Page1 of 2

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RICHARD J. VAZNAUGH (SBN: 173249)
LAW OFFICE OF RICHARD J. VAZNAUGH
1388 Sutter St., Ste 1000
San Francisco, CA 94109
Telephone: [phone]
Facsimile: 415-673-5606
[e-mail]
Attorney for Plaintiff
ROSALIND LOPEZ
MICHAEL D. BRUNO (SBN: 166805)
MICHAEL A. LAURENSON (SBN: 190023)
GORDON & REES LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
WAL-MART STORES, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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ROSALIND LOPEZ,

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Plaintiff,
vs.
WAL-MART STORES, INC. and DOES 1-20,
inclusive.
Defendant.

CASE NO. CV11-01632 LHK PSG
JOINT REQUEST FOR FURTHER
CONTINUANCE OF PRETRIAL
DEADLINES AND PROPOSED
ORDER

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The parties have made significant progress in working out the details of the settlement,

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which are complicated due to the fact that part of the settlement payment will be made by way of

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a structured settlement. The parties anticipate being able to reach agreement on all terms, but

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request additional time to complete the settlement and file a stipulation of dismissal.

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-1JOINT REQUEST FOR FURTHER CONTINUANCE OF PRETRIAL DEADLINES
CASE NO. CV11-01632 LHK

Case5:11-cv-01632-LHK Document74 Filed04/26/12 Page2 of 2

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Accordingly, because the settlement is progressing successfully but requires additional

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time and due diligence due to the structure, and both parties wish to avoid the cost of

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unnecessary trial preparation, the parties have stipulated and jointly request the following:

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1) That the deadline for filing a stipulation of dismissal be extended to April 30, 2012;

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2) That the pretrial conference be continued approximately one week to ____________

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______________and the date for oppositions to MILs and the due date for filing jury

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instructions, verdict forms, and proposed voir dire will now be on May 2, 2012; Or,

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in the alternative, that the current pretrial conference date be maintained and that,

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oppositions to MILs and the due date for filing jury instructions, verdict forms, and

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proposed voir dire be extended to May 1, 2012.
Dated: April 26, 2012

GORDON & REES LLP

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By: /s/Michael A. Laurenson
Michael D. Bruno
Michael A. Laurenson
Attorneys for Defendant
WAL-MART STORES, INC.

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Dated: April 26, 2012

LAW OFFICE OF RICHARD J.
VAZNAUGH

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By: /s/ Richard J. Vaznaugh
Richard J. Vaznaugh
Attorney for Plaintiff
ROSALIND LOPEZ
The parties shall file their stipulation of dismissal by April 30, 2012. The pretrial conference
remains as set for May 2, 2012. Oppositions to MILs and the due date for filing jury
IT IS SO ORDERED.
instructions, verdict forms, and proposed voir dire is extended to May 1, 2012.
IT IS SO ORDERED.
Dated: April 26, 2012
Dated

The Hon. Lucy Koh
United States District Court Judge

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WALM/1069481/12382117v.1

-2JOINT REQUEST FOR FURTHER CONTINUANCE OF PRETRIAL DEADLINES
CASE NO. CV11-01632 LHK