DANIEL J. THOMASCH NORMAN C. HILE, SBN 27599 (Admitted Pro Hac Vice) firstname.lastname@example.org email@example.com JULIE A. TOTTEN, SBN 166470 LAUREN J. ELLIOT firstname.lastname@example.org (Admitted Pro Hac Vice) DAVID A. PRAHL, SBN 233583 email@example.com firstname.lastname@example.org GIBSON, DUNN & CRUTCHER LLP ORRICK, HERRINGTON & SUTCLIFFE LLP 200 Park Avenue 400 Capitol Mall, Suite 3000 New York, New York 10166-0193 Sacramento, California 95814-4497 Telephone: 212.351.4000 Telephone: 916.447.9200 Facsimile: 212.351.4035 Facsimile: 916.329.4900 JULIAN W. POON, SBN 219843 MICHELE L. MARYOTT, SBN 191993 email@example.com firstname.lastname@example.org ALEXANDER K. MIRCHEFF, SBN 245074 GIBSON, DUNN & CRUTCHER LLP email@example.com 3161 Michelson Drive GIBSON, DUNN & CRUTCHER LLP Irvine, California 92612-4412 333 South Grand Avenue Telephone: 949.451.3800 Los Angeles, California 90071-3197 Facsimile: 949.451.4220 Telephone: 213.229.7000 Facsimile: 213.229.7520 Attorneys for Defendant PRICEWATERHOUSECOOPERS LLP MARKUN ZUSMAN & COMPTON LLP Jeffrey Compton William Baird 17383 Sunset Blvd., Suite A-380 Pacific Palisades, California 90272 Telephone: (310) 454-5900 Facsimile: (310) 454-5970 Attorneys for Plaintiffs [Additional Counsel on Signature Page]
STIPULATION AND ORDER RE CLASS CERTIFICATION MOTION
WHEREAS, on July 21, 2011, the Court issued an Order granting a Stipulation entered into between Plaintiffs Samuel Brandon Kress, Lac Anh Le, Jason Patterson, Lauren San Mateo, James Stekelberg, Jeffrey LaBerge, Willow Markham, Dana Blindbury, Jesse Kenny, Kelly C. Jones, Albert Liu, Daniel Gonzalez, David Beadles, and Antoine Powell (collectively, "Plaintiffs") and Defendant PricewaterhouseCoopers LLP ("Defendant" or "PwC") (together, "the parties") concerning a modified schedule for, among other things, briefing related to Plaintiffs' Rule 23 Class Certification Motion with respect to a putative class of unlicensed Associates and Senior Associates in PwC's Tax line of service in California ("Rule 23 TaX Motion") (see Docket No. 223).
WHEREAS, pursuant to the Court's July 21, 2011 Order, the deadline for Plaintiffs to file their Rule 23 Tax Motion is January 30, 2012, the deadline for PwC to file its opposition brief is March 15, 2012, and the deadline for Plaintiffs to file their reply brief is April 14, 2012;
WHEREAS, the parties have substantial discovery to complete relating to Plaintiffs' Rule 23 Tax Motion, including, but not limited to, written discovery and deposition discovery;
WHEREAS, the parties are in the process of completing briefing concerning Plaintiffs' Class Certification Motion with respect to a putative class of unlicensed Senior Associates in PwC's Audit division of its Assurance line of service in California ("Rule 23 Assurance Motion"), and Plaintiffs' reply brief on that Motion is due to be filed on February 13, 2012 (see Docket No. 252);
WHEREAS, the parties have met and conferred and agree that, given the substantial breadth of the putative class at issue in Plaintiffs' Rule 23 Tax Motion, an increase in the page limits applicable to the parties' opening, opposition and reply briefs would benefit the parties and the Court by helping to ensure that Plaintiffs' Rule 23 Tax Motion is fully and fairly briefed;
WHEREAS, the parties have met and conferred and agree that this stipulation is not for the purpose of delay and will further the effective and efficient administration of this litigation.
ACCORDINGLY, IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs and Defendant, by and through their respective undersigned counsel, as follows:
1. Plaintiffs' Rule 23 Tax Motion shall be due on or before July 31, 2012, PwC's opposition brief shall be due on or before September 28, 2012, and Plaintiffs' reply brief shall be due on or before November 13, 2012. Within 14 days of the filing of Plaintiffs' Rule 23 TaX Motion, the parties will meet and confer and propose a hearing date for approximately one month after the reply date.
2. The page limits applicable to the parties' briefs on Plaintiffs' Rule 23 Tax Motion shall be extended such that the parties' opening and opposition briefs shall be no more than 45 pages in length, and Plaintiffs' reply brief shall be no more than 20 pages in length.
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