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Luke Halton and Dennis Bier v. Valspar Corporation and Subsidiaries

July 22, 2011

LUKE HALTON AND DENNIS BIER,
INDIVIDUALLY AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED CURRENT AND FORMER
EMPLOYEES, PLAINTIFFS,
v.
VALSPAR CORPORATION AND SUBSIDIARIES, A DELAWARE CORPORATION, AND DOES 1 THROUGH 10, INCLUSIVE,
DEFENDANTS.



JOINT STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER

The parties to the above-referenced action stipulate as follows: WHEREAS, on March 3, 2011, the Court issued its Status (Pretrial Scheduling) Order (Docket No. 16) setting the following pretrial deadlines:

1. Pre-certification discovery cut-off: August 15, 2011;

2. Plaintiff's Motion for Class Certification: December 16, 2011;

3. Defendant's Opposition: December 30, 2011;

4. Plaintiff's Reply: January 6, 2012; and

5. Hearing on Class Certification: January 13, 2012.

WHEREAS, the parties are engaging in discovery;

WHEREAS, the parties have not yet finalized a stipulated protective order, in part, because Defendant must ensure that any such order complies with its obligations to third parties;

WHEREAS, the parties intend to continue working toward completing discovery and agree that additional time is necessary to prepare for class certification;

WHEREAS, the parties have met and conferred to determine a schedule for briefing and hearing the Plaintiff's Motion for Class Certification that accommodates previously scheduled travel and unavailability of counsel;

THE PARTIES THEREFORE STIPULATE AND REQUEST THAT the Court vacate the above-referenced deadlines, and set new deadlines as follows:

1. Pre-certification discovery cut-off: December 16, 2011;

2. Plaintiff's Motion for Class Certification: ...


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