Villa v. United Site Services of California, Inc
Filing
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ORDER by Judge Lucy H. Koh granting 38 Stipulation (lhklc2, COURT STAFF) (Filed on 8/21/2012)
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Robert J. Camp
rcamp@cochranfirm.com
Admitted Pro Hac Vice
THE COCHRAN FIRM – BIRMINGHAM, LLC
1929 3rd Avenue North, Suite 800
Birmingham, AL 35203
(205) 244-1115 – Phone
(205) 244-1171 - Facsimile
Attorneys for Plaintiffs
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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
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NELSON GONZALEZ VILLA,
Individually, and on behalf of Putative
Class Members,
Plaintiffs,
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vs.
UNITED SITE SERVICES OF
CALIFORNIA, INC.,
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Defendant.
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Case No.: No. 5:12-cv-00318-LHK
STIPULATION AND PROPOSED ORDER
TO EXTEND TIME TO FILE
PLAINTIFFS’ RULE 23 MOTION FOR
CLASS CERTIFICATION
Plaintiff, Nelson Gonzalez Villa, individually, and on behalf of putative class members
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(“Plaintiffs”), and Defendant, United Site Services of California, Inc. (“Defendant”), through
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their undersigned attorneys, stipulate and respectfully request that this Court approve an
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extension of time for Plaintiffs to file their Rule 23 Motion for Class Certification. As grounds
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for this extension, the parties state as follows:
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1.
On May 23, 2012 the Court entered its Minute Order and Case Management
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Order setting September 6, 2012 as the deadline for Plaintiffs’ Class Certification Motion;
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October 4, 2012 as the deadline for Defendant’s Opposition; and October 18, 2012 as the
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deadline for Plaintiffs’ Reply. The hearing on Class Certification Motion is November 8, 2012.
STIPULATION AND PROPOSED ORDER TO
EXTEND TIME TO FILE PLAINTIFFS’ RULE
23 MOTION FOR CLASS CERTIFICATION
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2.
The parties will be taking depositions in this matter the weeks of August 20, 2012
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and August 27, 2012 and mediation is scheduled for August 29, 2012. Deposition transcripts
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will not be available for review until September 5, 2012, one day before the current deadline for
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Plaintiffs to file their Class Certification Motion.
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3.
Counsel for Plaintiffs and Defendant have agreed to extend the current deadline
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for Plaintiffs’ Class Certification Motion to September 13, 2012, and extend the related
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deadlines a like number of days: October 11, 2012 for Defendant’s Opposition and October 25,
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2012 for Plaintiffs’ Reply.
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4.
The parties believe the requested extension will have no impact on the schedule
for this case given its early stages and would allow the hearing date to remain the same.
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WHEREFORE, PREMISES CONSIDERED, the parties stipulate to extend the time to
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file and serve Plaintiffs’ Rule 23 Motion for Class Certification to September 13, 2012,
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Defendant’s Opposition to October 11, 2012 and Plaintiffs’ Reply to October 25, 2012.
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Dated: August 17, 2012
Respectfully submitted,
Attorneys for Plaintiffs:
THE COCHRAN FIRM, LLC
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/s/ Robert J. Camp
ROBERT J. CAMP
rcamp@cochranfirm.com
Admitted Pro Hac Vice
1929 3rd Avenue North, Suite 800
Birmingham, AL 35203
(205) 244-1115 – Phone
(205) 244-1171 - Facsimile
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MITCHELL G. ALLEN
mallen@theallenlawfirm.com
Admitted Pro Hac Vice
JACOBY & MEYERS
1929 3rd Avenue North, Suite 600
Birmingham, AL 35203
(800) 411-4529 – Phone
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STIPULATION AND PROPOSED ORDER TO
EXTEND TIME TO FILE PLAINTIFFS’ RULE
23 MOTION FOR CLASS CERTIFICATION
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FERNANDO CHAVEZ
fchavez@chavez-deleon.com
California Bar No. 86902
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LAW OFFICES OF FERNANDO CHAVEZ
1530 The Alameda, Suite 301
San Jose, CA 95126
(408) 971-3113 – Phone
(408) 971-0107 – Facsimile
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Attorneys for Defendant:
BERLINER COHEN
/s/ Susan E. Bishop
SUSAN E. BISHOP
Susan.Bishop@berliner.com
10 Almaden Blvd., Eleventh Floor
San Jose, CA 95113
(408) 286‐5800 – Phone
(408) 998‐5388 – Facsimile
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ECF ATTESTATION
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I, Robert J. Camp, am the ECF user whose ID and password are being used to file the
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foregoing on August 16, 2012. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that
Susan E. Bishop has concurred in this filing.
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/s/ Robert J. Camp
ROBERT J. CAMP
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ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: August 21
, 2012
UNITED STATES DISTRICT COURT
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STIPULATION AND PROPOSED ORDER TO
EXTEND TIME TO FILE PLAINTIFFS’ RULE
23 MOTION FOR CLASS CERTIFICATION
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