UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
October 22, 2010
DANIELLE WARREN, AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFF,
PAYCHEX, INC. DEFENDANT.
The opinion of the court was delivered by: N Joseph C. Spero United States Magistrate Judge
STIPULATION AND [PROPOSED] ORDER PERMITTING DISCLOSURE OF CONTACT INFORMATION OF PUTATIVE CLASS MEMBERS
Plaintiff Danielle Warren ("Plaintiff") and Defendant Paychex, Inc. ("Defendant") (collectively, the "Parties"), by and through their respective counsel of record, stipulate and agree as follows:
WHEREAS, the Parties have agreed to mediate this putative class action case on January 12, 2011; and interview putative class members, and therefore seeks putative class member contact information from Defendant; and member contact information. Per those discussions, Defendant agreed to produce contact information for certain putative class members, but, due to the potential privacy concerns of providing the personal information of its employees, Defendant will agree to produce such contact information only if the Court first authorizes the disclosure (and according to other agreed-upon terms, such as the putative class members whose information will be disclosed, 15 the method of disclosure, etc.); and order permitting Defendant to disclose putative class member contact information; and of putative class member contact information. However, in order to facilitate discovery in advance of mediation, Plaintiff agreed to Defendant's proposal to request Court authorization 21 for disclosure.
information of the putative class by Defendant, no later than seven (7) business days after Defendant's Counsel receives notice of the Court's executed Order, Defendant will deliver to Plaintiff's Counsel a list of the names, last-known addresses, and last-known phone numbers
THE PUTATIVE CLASS
WHEREAS, for the mediation to be productive, Plaintiff seeks to contact and
WHEREAS, Counsel for the Parties conferred about disclosure of putative class
WHEREAS, Defendant proposed that the Parties stipulate to ask the Court to issue an
WHEREAS, Plaintiff does not believe Court authorization is necessary for disclosure
The parties hereby stipulate and agree as follows.
1. Provided the Court issues an Order authorizing disclosure of the contact of all putative Class Members, in an electronic spreadsheet such as Microsoft Excel. For purposes of this Stipulation and proposed Order, "putative Class Members" shall mean all persons who have been employed in California by Defendant Paychex, Inc. as Sales Representatives in the first six-months of their employment in that position in California at any time since May 10, 2006.
PURSUANT TO THE ABOVE-NOTED STIPULATION, THE COURT HEREBY ORDERS THAT:
Defendant is authorized to disclose putative class member contact information to Plaintiff, subject to the stipulated protective order that is in place in this case, and also subject to the above stipulated terms agreed to by the Parties.
IS SO ORDERED.
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