Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Official citation and/or docket number and footnotes (if any) for this case available with purchase.

Learn more about what you receive with purchase of this case.

David Baba and Ray Ritz, Individually v. Hewlett Packard Company

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


January 11, 2012

DAVID BABA AND RAY RITZ, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED,
PLAINTIFFS,
v.
HEWLETT PACKARD COMPANY,
DEFENDANT.

The opinion of the court was delivered by: Richard Seeborg United States District Judge

Barbara Quinn Smith (Ohio Bar 0055328) (pro hac vice) 2 MADDOX HARGETT &CARUSO 9933 Johnnycake Ridge Road 3 Suite 3F Mentor, OH 44060 4 Telephone: 440-354-4010 Facsimile: 440-848-8175 5 bqsmith@mhclaw.com 6 (Additional Counsel listed below) 7 Attorneys for David Baba and Ray Ritz Samuel Liversidge, SBN 180578 Kristofor T. Henning (Pro Hac Vice) SLiversidge@gibsondunn.com Franco A. Corrado (Pro Hac Vice) 9 David Han, SBN 247789 MORGAN, LEWIS & BOCKIUS LLP DHan@gibsondunn.com 1701 Market Street 10 GIBSON, DUNN & CRUTCHER LLP 333 Philadelphia, PA 19103 11 South Grand Avenue Telephone: 215.963.5000 Los Angeles, California 90071-3197 Telephone: Facsimile: 215.963.5001 12 213.229.7000 Facsimile: 213.229.7520 khenning@morganlewis.com fcorrado@morganlewis.com 8 Attorneys for Defendant Hewlett-Packard Company

STIPULATION REGARDING ENLARGMENT OF TIMERELATED TO PLAINTIFFS' ANTICIPATED MOTION FOR CLASS CERTIFICATION

Through this Stipulated Request and [Proposed] Order, Plaintiffs David Baba and Ray Ritz ("Plaintiffs") and Defendant Hewlett-Packard Company ("HP") stipulate and agree to 3 continue the hearing on Plaintiffs' anticipated motion for class certification and to extend the 4 schedule for the related briefing as set forth below, and jointly request that the Court approve this 5 extension pursuant to L.R. 6-2. 6

WHEREAS, during the Case Management Conference held on August 11, 2011, the 7 parties proposed a hearing date of May 10, 2012 for Plaintiffs' anticipated motion for class 8 certification; 9 10 agreed upon briefing schedule for Plaintiffs' anticipated motion for class certification; 11 12 schedule for Plaintiffs' anticipated motion for class certification: 13

WHEREAS, at that conference, the Court further requested that the parties submit an WHEREAS, on August 18, 2011, the parties submitted the following stipulated briefing

Case Schedule

Deadline for filing of anticipated class February 8, 2012 15 certification motion 16 HP's opposition to class certification due March 22, 2012 Plaintiffs' reply in support of class certification April 19, 2012 due 21 discovery regarding Plaintiffs' claims and anticipated motion for class certification; 22 23 pending; 24

WHEREAS, since that time, the parties have engaged, and continue to engage, in formal

WHEREAS, two discovery disputes have been presented to the Court and remain

WHEREAS, the parties negotiated in good faith over the form of a Stipulated Protective

Order governing the production of sensitive confidential and highly confidential information in 26 this matter; 27 28

WHEREAS, after the parties reached an impasse in those negotiations, Plaintiffs filed a Motion for Protective Order on August 5, 2011; 3 6 protective order, and Plaintiffs have agreed that those documents will not be disclosed to anyone 7 other than counsel; 8 9 class certification, Plaintiffs anticipate the need to consult with an expert regarding the evidence 10 produced thus far, and thus the need for that expert to review confidential documents; 11

WHEREAS, HP filed its response to Plaintiffs' motion on August 19, 2011;

WHEREAS, an order resolving that motion has yet to issue;

WHEREAS, in the interim, HP has produced documents that may be subject to the

WHEREAS, in order to conduct depositions prior to filing the anticipated motion for

WHEREAS, Plaintiffs are unable to do so until a ruling is received on the pending

Motion for Protective Order; 13

14 regarding the production of materials identifying potential putative class members that remains 15 pending; 16

17 to obtain evidence relevant to their anticipated motion for class certification and, therefore, 18 sought HP's agreement to extend the briefing schedule and hearing for Plaintiffs' anticipated 19 20 motion for class certification;

WHEREAS, HP does not oppose Plaintiffs' request for an extension;

WHEREAS, the parties have neither agreed to nor sought a prior extension of time on the class certification briefing schedule or continuance of the hearing date;

ACCORDINGLY, pursuant to Civil Local Rules 6-2 and 7-12, the parties hereby 25 stipulate to, and request the Court's approval of, the following extended class certification 26 briefing schedule:

WHEREAS, the parties also submitted a Joint Discovery Dispute on September 27, 2011

WHEREAS, Plaintiffs anticipate that this information may be necessary to enable them

Case Schedule

Deadline for filing of anticipated class April 6, 2012 certification motion 3 HP's opposition to class certification due May 21, 2012 4 Plaintiffs' reply in support of class certification June 18, 2012 5 due Hearing on anticipated motion for class To be determined by the Court 6 certification July 5, 2012 at 1:30 p.m.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

20120111

© 1992-2012 VersusLaw Inc.



Buy This Entire Record For $7.95

Official citation and/or docket number and footnotes (if any) for this case available with purchase.

Learn more about what you receive with purchase of this case.