Romero v. Flowers Bakeries, LLC

Filing 40

ORDER APPROVING 39 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE. Case Management Statement due by 8/20/2015. Initial Case Management Conference set for 8/27/2015 01:30 PM in Courtroom 3, 5th Floor, San Jose. Signed by Hon. Beth Labson Freeman on 6/25/2015. (blflc2, COURT STAFF) (Filed on 6/25/2015)

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Jennifer S. Romano (CSB No. 195953)
[e-mail]

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CROWELL & MORING LLP
515 South Flower St., 40th Floor
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]

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Joel D. Smith (CSB No. 244902)
[e-mail]

Rebecca M. Suarez (CSB No. 284853)
[e-mail]

CROWELL & MORING LLP
275 Battery Street, 23rd Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415.986.2827

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Attorneys for FLOWERS BAKERIES, LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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KELLY ROMERO, on behalf of herself and
others similarly situated,

CLASS ACTION
Plaintiff,

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Case No. 5:14-cv-05189

v.
FLOWERS BAKERIES, LLC dba
NATURE’S OWN, a Georgia limited
liability company, and DOES 1 through 50,
inclusive,

STIPULATION AND [PROPOSED]
ORDER CONTINUING JULY 9, 2015
CASE MANAGEMENT STATEMENT
AND JULY 16, 2015 CASE
MANAGEMENT CONFERENCE

Defendant.

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C ROWELL
& M ORING LLP
ATTO RNEY S AT LAW

Case No. 5:14-cv-05189
STIPULATION TO CONTINUE CASE MANAGEMENT STATEMENT
AND CASE MANAGEMENT CONFERENCE

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Pursuant to Northern District of California Local Rule 6-2, Plaintiff Kelly Romero and

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Defendant Flowers Bakeries, LLC (“Flowers”), by and through their respective attorneys, hereby

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stipulate as follows:

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WHEREAS, on May 6, 2015, the Court granted in part and denied in part Flowers’
motion to dismiss the original complaint in this action. (Doc. No. 35.)
WHEREAS, pursuant to a stipulation between the parties and this Court’s June 3, 2015

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Order approving the stipulation, the deadline to file Plaintiff’s First Amended Complaint (“FAC”)

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is July 6, 2015. (Doc. No. 38.)

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WHEREAS, the parties’ joint Case Management Statement is due July 9, 2015 and the
Initial Case Management Conference is scheduled for July 16, 2015. (Doc. No. 36.)
WHEREAS, Flowers anticipates that it will likely respond to the FAC by filing another

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motion to dismiss or stay the action (subject to an analysis of the allegations in the FAC after it is

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filed). In addition, counsel for Flowers has a scheduling conflict with the currently scheduled

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July 16, 2015 Case Management Conference.

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THEREFORE, Flowers and Ms. Romero stipulate and respectfully request that the Court

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continue the Case Management Statement to Thursday, August 20, 2015, and the Case

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Management Conference to Thursday, August 27, 2015, or as soon thereafter as the Court may

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designate.

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Dated: June 24, 2015

CROWELL & MORING, LLP
By:

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Joel D. Smith
Attorneys for Defendant
Flowers Bakeries, LLC

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/s/ Joel D. Smith

Dated: June 24, 2015

COUNSELONE, P.C.
By:

/s/ Anthony Orshansky
Anthony Orshansky
Attorneys for Plaintiff
Kelly Romero

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C ROWELL
& M ORING LLP
ATTO RNEY S AT LAW

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Case No. 5:14-cv-05189
STIPULATION TO CONTINUE CASE MANAGEMENT STATEMENT
AND CASE MANAGEMENT CONFERENCE

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[PROPOSED ORDER]
PURSUANT TO STIPULATION, IT IS SO ORDERED,

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Date: June 25, 2015
Hon. Beth Labson Freeman
United States District Judge

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I, Joel D. Smith, am the ECF User whose ID and password are being used to file this

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document. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that concurrence in the

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filing of the document has been obtained from each of the other signatories.

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By:

/s/ Joel D. Smith
Joel D. Smith

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C ROWELL
& M ORING LLP
ATTO RNEY S AT LAW

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Case No. 5:14-cv-05189
STIPULATION TO CONTINUE CASE MANAGEMENT STATEMENT
AND CASE MANAGEMENT CONFERENCE