Lazarin et al v. Pro Unlimited, Inc. et al

Filing 19

ORDER on Joint Stipulation to Extend Time. Case Management Statement due by 11/15/2011. Rule 26(f) Report due by 11/15/2011. Initial Case Management Conference set for 11/22/2011 at 01:30 PM in Courtroom 2, 5th Floor, San Jose. Signed by Magistrate Judge Howard R. Lloyd on 9/28/11. (hrllc1, COURT STAFF) (Filed on 9/28/2011)

** E-filed September 28, 2011 **
** E-filed {XXX} **

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JACKSON LEWIS LLP
CARY G. PALMER, Cal. Bar No. 186601
[e-mail]
HEATH A. HAVEY, Cal Bar No. 244087
[e-mail]
801 K Street, Suite 2300
Sacramento, California 95814
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant
PrO Unlimited, Inc.

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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - SAN JOSE DIVISION

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MICHAEL LAZARIN, STEPHEN KOHLER,
and PAUL CAPANO, individually and on
behalf of other members of the general public
similarly situated, and as aggrieved employees
pursuant to the Private Attorneys General Act
(“PAGA”)

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Plaintiffs,

Case No. 5:11-CV-03609-HRL
JOINT STIPULATION TO EXTEND TIME
FOR FILING RULE 26(f) REPORT, INITIAL
DISCLOSURES, AND CMC CONFERENCE;
AND [PROPOSED] ORDER
(AS MODIFIED BY THE COURT)

v.
PRO UNLIMITED, INC., JUNIPER
NETWORKS, INC., JUNIPER
NETWORKS HOLDINGS
INTERNATIONALO, INC., and JUNIPER
NETWORKS (US), INC.
Defendants.

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TO THE HONORABLE COURT AND TO ALL PARTIES AND COUNSEL:

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WHEREFORE, pursuant to Federal Rule of Civil Procedure 16(b)(4), and for good cause,

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plaintiffs Michael Lazarin, Stephen Kohler, and Paul Capano (“Plaintiffs”), and defendant PrO

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Unlimited, Inc. (“Defendant”), by and through their respective attorneys of record, hereby jointly

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stipulate and request that the Court vacate the dates set forth in the Order Setting Initial Case

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Management Conference and ADR Deadlines filed on July 22, 2011, and that the Court continue

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such dates as set forth in the stipulation below. The reason for this request and stipulation is that

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Defendant recently retained new counsel and filed a Notice of Withdrawal and Substitution of
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Joint Stipulation to Extend Time For Rule 26(f) Report, Initial
Disclosures, and CMC Conference; and [Proposed] Order

Lazarin, et al. v. PrO Unlimited, Inc., et al.
USDC ND Case No. 5:11-cv-03609-HRL

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Counsel for Defendant on September 27, 2011. As a result, Defendant’s new counsel requires 30

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days to review the facts and allegations in the case to meaningfully participate. As a courtesy,

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Plaintiffs do not oppose and have agreed to stipulate to the request for extension.

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WHEREFORE, the Parties hereby stipulate and request as follows:

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1.

The current deadline of September 27, 2011, to file the Rule 26(f) Report, to

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complete initial disclosures, to state objections in the Rule 26(f) Report, and to file

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a Case Management Statement per the Court’s Standing Order re Contents of Joint
November 15, 2011
Case Management Statement, be continued for 30 calendar days to October 27,

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2011;

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2.

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3.

The current deadline of September 27, 2011, to file a joint case management
November 15, 2011
statement, be continued for 30 calendar days to October 27, 2011; and
The Initial Case Management Conference presently set for October 4, 2011, be
November 22, 2011
continued to November 3, 2011.

IT IS SO STIPULATED.

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Date: September 27, 2011

JACKSON LEWIS LLP

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By:

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Attorneys for Defendant
PrO Unlimited, Inc.

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/s/
Cary G. Palmer

Date: September 27, 2011

RUKIN HYLAND DORIA & TINDALL LLP

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By:

/s/
Peter Rukin
Attorneys for Plaintiffs

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Joint Stipulation to Extend Time For Rule 26(f) Report, Initial
Disclosures, and CMC Conference; and [Proposed] Order

Lazarin, et al. v. Pro Unlimited, Inc., et al.
USDC ND Case No. 5:11-cv-03609-HRL

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FOR GOOD CAUSE, IT IS HEREBY ORDERED AS FOLLOWS:

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1.

The current deadline of September 27, 2011, to file the Rule 26(f) Report, to

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complete initial disclosures, to state objections in the Rule 26(f) Report, and to file

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a Case Management Statement per the Court’s Standing Order re Contents of Joint

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Case Management Statement, is hereby continued for 30 calendar days to October
November 15, 2011
27, 2011;

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2.

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3.

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The current deadline of September 27, 2011, to file a joint case management
November 15, 2011
statement, is hereby continued for 30 calendar days to October 27, 2011; and
The Initial Case Management Conference presently set for October 4, 2011, is
November 22, 2011
hereby continued to November 3, 2011, at 1:30 pm.

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September 28, 2011
Dated: ____________________________

__________________________________
HONORABLE HOWARD R. LLOYD
MAGISTRATE JUDGE OF THE
UNITED STATES DISTRICT COURT

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4812-1623-7067, v. 1

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Joint Stipulation to Extend Time For Rule 26(f) Report, Initial
Disclosures, and CMC Conference; and [Proposed] Order

Lazarin, et al. v. Pro Unlimited, Inc., et al.
USDC ND Case No. 5:11-cv-03609-HRL

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C 11-03609 HRL Notice will be electronically mailed to:

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Carol Josephine Morganstern
Peter Scott Rukin
Cary G. Palmer
Madonna Ann Herman
Alfred Michael DeLaCruz
Dennis Bruce Kass
Heath Aaron Havey
Richard Gustavo Garcia

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[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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For the Northern District of California

United States District Court

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Counsel are responsible for distributing copies of this document to co-counsel who have not
registered for e-filing under the court’s CM/ECF program.