Rosh v. Indeed, Inc.

Filing 22

STIPULATION AND ORDER 21 to Adjust Case Management Schedule. Case Management Conference set for 4/25/2014 10:30 AM in Courtroom 6, 4th Floor, San Jose. Joint Case Management Statement is due 4/18/2014. Signed by Judge Ronald M. Whyte on 12/11/13. (jgS, COURT STAFF) (Filed on 12/11/2013)

1

4

ADAM W. HANSEN (State Bar No. 264241)
[e-mail]
NICHOLS KASTER LLP
One Embarcadero Center, Suite 720
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]

5

Attorney for Plaintiff ADAM ROSH

2
3

6
7
8
9
10
11
12
13
14
15
16

MALCOLM A. HEINICKE (State Bar No. 194174)
[e-mail]
JESLYN A. MILLER (State Bar No. 274701)
[e-mail]
MUNGER, TOLLES & OLSON LLP
560 Mission Street, 27th Floor
San Francisco, California 94105-2907
Telephone:
[phone]
Facsimile:
[phone]
KATHERINE M. FORSTER (State Bar No. 217609)
[e-mail]
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue, 35th Floor
Los Angeles, CA 90071-1560
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant INDEED, INC.

17
UNITED STATES DISTRICT COURT

18

NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

19
20
21

ADAM ROSH, individually, on behalf of
others similarly situated, and on behalf of the
general public,

22
23
24

Plaintiff,
vs.

Defendant.

26

STIPULATION AND []
ORDER TO ADJUST CASE
MANAGEMENT SCHEDULE
Case Management Conference

INDEED, INC.,

25

Case No. 5:13-cv-03751-RMW

Date:
Time:
Judge:
Crtrm:

December 13, 2013
10:30 a.m.
Hon. Honorable Ronald M. Whyte
6

Complaint filed: August 13, 2013

27
28

STIPULATION AND [] ORDER TO
ADJUST CASE MANAGEMENT SCHEDULE
22295237.1

1

Pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, Local Rule 6-2, and Local

2

Rule 7-12, Plaintiff Adam Rosh (“Rosh”) and Defendant Indeed, Inc. (“Indeed”) hereby stipulate

3

and respectfully request that the Court reschedule the case management conference in this matter

4

to April 25, 2014, or as soon thereafter as the Court is available.

5
6

WHEREAS, Rosh filed a Class and Collective Action Complaint in this matter on August
13, 2013 (Dkt. No. 1);

7

WHEREAS, on September 17, 2013, the Court ordered that the parties submit a Joint

8

Case Management Statement by December 6, 2013, and set a Case Management Conference for

9

December 13, 2013 (Dkt. No. 15);

10
11

WHEREAS, Indeed filed an Answer to the Class and Collective Action Complaint on
October 4, 2013 (Dkt. No. 16);

12

WHEREAS, the parties agreed in the Stipulation and Order entered by this Court on

13

November 19, 2013, to submit this case to private mediation to be completed by March 31, 2014

14

(Dkt. No. 19);

15

WHEREAS, in the joint case management statement submitted on November 26, 2013,

16

the parties agreed to postpone all discovery in this matter until after the conclusion of mediation,

17

and further agreed that, in the event mediation is unsuccessful, the parties will serve a

18

supplemental case management statement and discovery plan within 21 days of the conclusion of

19

mediation (Dkt. No. 20 at 3, 7); and

20

WHEREAS, the parties believe that, in light of the planned mediation and postponed

21

discovery, there will be no discovery issues to resolve until after the mediation in this matter;

22

THEREFORE, Plaintiff Rosh and Defendant Indeed, through the undersigned counsel,

23

hereby stipulate and request that the Court continue the Case Management Conference in this

24

matter to April 25, 2014, or as soon thereafter as the Court is available, in order to give the parties

25

sufficient time prior to the Conference to complete mediation and to submit a supplemental

26

discovery plan.

27

///

28

///
-122295237.1

STIPULATION AND [] ORDER TO
ADJUST CASE MANAGEMENT SCHEDULE

1

Respectfully submitted,

2
Dated: December 6, 2013

3

ADAM W. HANSEN
NICHOLS KASTER LLP

4
5

By:

6

/s/ Adam W. Hansen
ADAM W. HANSEN

Attorneys for Plaintiff
ADAM ROSH

7
8
9
Dated: December 6, 2013

10
11

Munger, Tolles & Olson LLP
MALCOLM A. HEINICKE
KATHERINE M. FORSTER
JESLYN A. MILLER

12
13

By:

14

/s/ Katherine M. Forster
KATHERINE M. FORSTER

Attorneys for Defendant,
INDEED, INC.

15
16
17

I, Katherine M. Forster, attest that I have obtained concurrence from Adam W. Hansen in

18

the filing of this Stipulated Request to Adjust Discovery Deadline. See N.D. Cal. Civ.

19

L.R. 5-1(i)(3).

20
21

[] ORDER

22

Pursuant to the stipulation of counsel, IT IS SO ORDERED.

23
24

Dated:
Hon. Honorable Ronald M. Whyte
District Court Judge

25
26
27
28

-222295237.1

STIPULATION AND [] ORDER TO
ADJUST CASE MANAGEMENT SCHEDULE