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Wayne Koh, On Behalf of Himself and All Others Similarly Situated v. S.C. Johnson & Son

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


May 12, 2011

WAYNE KOH, ON BEHALF OF HIMSELF AND ALL OTHERS SIMILARLY SITUATED
PLAINTIFF,
v.
S.C. JOHNSON & SON, INC.,
DEFENDANT.

The opinion of the court was delivered by: Ronald M. Whyte United States District Judge

REESE RICHMAN LLP Michael R. Reese (Cal. State Bar. No. 206773) Kim E. Richman Belinda L. Williams 875 Avenue of the Americas, 18th Floor New York, New York 10001 Telephone: (212) 643-0500 Facsimile (212) 253-4272 *E-FILED - 5/12/11* Attorneys for Plaintiff and the Proposed Class KIRKLAND & ELLIS LLP Jeffrey Willian, P.C. Robert B. Ellis, P.C. Bradley H. Weidenhammer Nickolas A. Kacprowski (Cal. State Bar. No. 242684) 9 Amy E. Crawford 300 North LaSalle Street Chicago, Illinois 60654 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Attorneys for Defendant S.C. Johnson & Son, Inc. 13

STIPULATION AND [] ORDER EXTENDING DISCOVERY AND CLASS CERTIFICATION BRIEFING DEADLINES

Plaintiff Wayne Koh and Defendant SC Johnson & Son, Inc. (collectively, the "Parties"), by 25 their attorneys, hereby stipulate, contingent upon permission of the Court, to the following extension 26 of the current discovery and class certification briefing deadlines. The Parties also hereby 27 respectfully request that the Court order the stipulated schedule: 28

Stipulation and [ Order Extending Case No. 09-cv-00927 RMW Discovery and Briefing Schedule

STIPULATION

WHEREAS, on January 19, 2011, the Court entered the following schedule (Dkt. 72);

Class Certification Briefing:

Defendant's response to motion for class certification: April 11, 2011

Plaintiff's reply in support of motion for class certification: May 9, 2011

Hearing on Plaintiff's Motion for Class Certification: May 27, 2011

Discovery:

Fact discovery cut-off: May 9, 2011

Plaintiff's expert reports due: April 25, 2011

Depositions of plaintiff's experts: May 9, 2011

Defendant's expert reports due: May 23, 2011

Depositions of defendant's experts: June 6, 2011

Summary Judgment Briefing:

Motions for summary judgment: June 22, 2011

Responses to motions for summary judgment: July 22, 2011

Replies in support of motions for summary judgment: August 22, 2011

Last Day to Hear Dispositive Motions: September 16, 2011, at 9:00 a.m.

Trial:

Pretrial Conference: October 27, 2011 at 2:00 p.m.

Jury Trial: November 14, 2011 at 1:30 p.m.

WHEREAS, in addition to the dates listed above, Plaintiff also filed a motion to compel certain production of documents from Defendant that is scheduled for hearing on May 3, 2011;

WHEAREAS, pursuant to a joint stipulation between the Parties reached in respond to a motion to compel filed by Plaintiffs, Defendant's Chief Executive Officer, H. Fisk Johnson, is to sit 24 for his deposition prior to the current discovery cut-off date of May 9, 2011 (Dkt. 111); 25

WHEREAS, on April 11, 2011, Defendants served several experts reports in support of their opposition to Plaintiff's Motion for Class Certification; 27 28

WHEREAS, Plaintiff needs to depose Defendant's experts prior to filing Plaintiff's Reply in Support of Plaintiff's Motion for Class Certification, which is currently due on May 9, 2011, 3

WHEAREAS, Plaintiff subpoenaed the experts on April 15, 2011 for their depositions;

WHEREAS, Defendant's experts are not available for deposition prior to May 9, 2011;

WHEREAS, the Parities recently entered serious settlement negotiations, and are in the process of retaining a private mediator; 7

WHEREAS, the Parties believe that it is in the best interest of efficiency and judicial economy if they focus their efforts to determine if the matter can be settled at this point without 9 further discovery and motion practice; 10

WHEREAS, the Parties have, to date, requested two extensions of the discovery deadline and trial date, which was granted by the Court on February 2, 2010 and January 19, 2011; 12

WHEREAS, the Parties estimate that they need an additional sixty (60) days to meet with a mediator and determine whether this action can be settled; 14

THE FOLLOWING SCHEDULE, UPON PERMISSION OF THE COURT, IS AGREED

TO BY THE PARTIES:

Class Certification Briefing:

Plaintiff's reply in support of motion for class certification: July 11, 2011

Hearing on the Motion for Class Certification: July 29, 2011

Discovery:

Hearing on Plaintiff's Motion to Compel (Dkt. 93): on or before June 21, 2011

Fact discovery cut-off: July 11, 2011

Deposition of CEO H. Fisk Johnson: before July 11, 2011

Plaintiff's expert reports due: June 27, 2011

Depositions of plaintiff's experts: July 11, 2011

Defendant's expert reports due: July 25, 2011

Depositions of defendant's experts: August 8, 2011

Summary Judgment Briefing:

Motions for summary judgment: August 22, 2011

Responses to motions for summary judgment: September 22, 2011

Replies in support of motions for summary judgment: October 21, 2011

Last Day to Hear Dispositive Motions: November 18, 2011, at 9:00 a.m.

Trial:

Pretrial Conference: January 5, 2012 at 2:00 p.m.

Jury Trial: January 17, 2012 at 1:30 p.m.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10

[] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

20110512

© 1992-2011 VersusLaw Inc.



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