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Marshall Field, Individually and On Behalf of All Other Similarly Situated Persons v. American Mortgage Express Corp.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA


March 30, 2011

MARSHALL FIELD, INDIVIDUALLY AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED PERSONS, PLAINTIFFS,
v.
AMERICAN MORTGAGE EXPRESS CORP., A PENNSYLVANIA CORPORATION AND GEVITY HR, INC., A FLORIDA CORPORATION,
DEFENDANTS.

The opinion of the court was delivered by: Honorable Judge Marilyn H. Patel

California Northern District Federal District Court

Lorraine P. Ocheltree (SBN 151791) Allegra A. Jones (SBN 236518) DUANEMORRIS LLP One Market, Spear Tower, Suite 2200 San Francisco, CA 94105-1127 Telephone: 415.957.3000 Facsimile: 415.957.3001 E-Mail: lpocheltree@duanemorris.com aajones@duanemorris.com Eric P. Berezin (Admitted Pro Hac Vice) DUANEMORRIS LLP Atlantic Center Plaza 1180 West Peachtree Street NW, Suite 700 Atlanta, GA 30309-3448 Telephone: 404.253.6900 Facsimile: 404.253.6901 E-mail: epberezin@duanemorris.com Attorneys for Defendant GEVITY HR, INC. Harry G. Lewis (SBN 157705) Gordon W. Renneisen (SBN 129794) Julie A. Marquis (SBN 178466) CORNERSTONE LAW GROUP 595 Market Street, Suite 2360 San Francisco, CA 94105 Telephone: (415) 974-1900 Facsimile: (415) 974-6433 Attorneys for Plaintiff MARSHALL FIELD and all other similarly situated persons

JOINT STIPULATION AND [PROPOSED] ORDER REGARDING MOTION FOR SUMMARY JUDGMENT SCHEDULE

Plaintiff Marshall Field ('Field"), by and through his undersigned counsel, and Defendant Gevity HR, Inc. ("Gevity"), by and through its undersigned counsel, hereby enter into the following Joint Stipulation:

WHEREAS this Court issued an Order regarding the dates for the filing of the parties' respective motions for summary judgment and/or summary adjudication of issues ("Motions");

WHEREAS, the parties are seeking to informally resolve a discovery dispute prior to filing heir Motions, and need additional time to meet and confer.

NOW, THEREFORE, Field and Gevity hereby stipulate and agree as follows:

1. The deadline for the parties to file their Motions is continued to May 2, 2011;

2. The deadline for the parties to file their opposition to the Motions is continued to May 16, 2011;

3. The deadline for the parties to file their reply to any opposition to the Motions is continued to May 23, 2011; and

4. The hearing on the Motions shall be conducted on June 6, 2011. or such other date as the court may set.

Dated: March 29, 2011 DUANE MORRIS LLP By: Eric P. Berezin Lorraine P. Ocheltree Allegra A. Jones Attorneys for Defendant GEVITY HR, INC. Dated: March 29, 2011 CORNERSTONE LAW GROUP By: Harry G. Lewis Attorneys for Plaintiff MARSHALL FIELD

A CT C O

T R

IT IS SO ORDERED. ES I

DIST

S

T

D U E R

Dated: March _, 2011

I

N IS SO ORDERED

T

T

IT Judge of the Unit

U ed States District Court A

I N

N H. Patel R

O Judge Marilyn O R F

T L

H

I

E

R C

A

N F DIS O

TRICT

20110330

© 1992-2011 VersusLaw Inc.



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