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

Filing 31

**Docket Text Edited and Corrected** STIPULATION AND ORDER re 30 . Case Management Statement due by 3/20/2012. Rule 26 Meeting Report due by 3/20/2012. Initial Case Management Conference set for 3/27/2012 01:30 PM in Courtroom 2, 5th Floor, San Jose. Signed by Magistrate Judge Howard R. Lloyd on 1/19/12. (hrllc1, COURT STAFF) (Filed on 1/19/2012) Modified on 1/19/2012 (hrllc1, COURT STAFF).

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** E-filed January 19, 2012 **

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

Plaintiffs,
v.
PRO UNLIMITED, INC., JUNIPER
NETWORKS, INC., JUNIPER
NETWORKS HOLDINGS
INTERNATIONAL, 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 defendants PrO

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Unlimited, Inc. (“PrO”), Juniper Networks, Inc., Juniper Network Holdings International, Inc.,

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and Juniper Networks (US), Inc., by and through their respective attorneys of record, hereby

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jointly stipulate and request the Court to vacate the dates set forth in the Order granting the Joint

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Stipulation to Extend Time for Filing Rule 26(f) Report, Initial Disclosures, and CMC
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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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Conference, filed on November 23, 2011, and to continue such dates as set forth in the stipulation

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below.

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The parties are continuing to explore early class-wide resolution and have reached a

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tentative understanding. As a result, the parties respectfully request additional time to focus on

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final resolution of this case.

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WHEREFORE, the parties hereby jointly stipulate and request as follows:

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1.

The current deadline of January 17, 2012, 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, be continued to March 20, 2012;

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2.

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statement, be continued to March 20, 2012; and

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3.

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The Initial Case Management Conference presently set for January 24, 2012, be
continued to March 27, 2012.

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The current deadline of January 17, 2012, to file a joint case management

IT IS SO STIPULATED.
Date: January 18, 2012

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By: /s/ [Peter Rukin] as approved on 1/18/12
Peter Rukin
Attorneys for Plaintiffs

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RUKIN HYLAND DORIA & TINDALL LLP

Date: January 18, 2012

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JACKSON LEWIS LLP
By: /s/ [Cary G. Palmer]
Cary G. Palmer
Attorneys for Defendant
PrO Unlimited, Inc.

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Date: January 18, 2012

ALLEN MATKINS LECK GAMBLE
MALLORY & NATSIS LLP

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By: /s/ [Baldwin J. Lee] as approved on 1/18/12
Baldwin J. Lee
Attorneys for Defendant
Juniper Networks, Inc., Juniper Network
Holdings, International, Inc. and Juniper
Networks (US), Inc.

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///

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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

1

FOR GOOD CAUSE, IT IS HEREBY ORDERED AS FOLLOWS:

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1.

The current deadline of January 17, 2012, 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 be continued to March 20, 2012;

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2.

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The current deadline of January 20, 2012, to file a joint case management
statement, be continued to March 20, 2012; and

3.

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The Initial Case Management Conference presently set for January 24, 2012, be
continued to March 27, 2012.

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January 19, 2012
Dated: ____________________________

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

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4832-8419-9438, 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