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Chris Werdebaugh, Individually and On Behalf of All Others v. Blue Diamond Growers

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION


August 28, 2012

CHRIS WERDEBAUGH, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFF,
v.
BLUE DIAMOND GROWERS,
DEFENDANT.

The opinion of the court was delivered by: Honorable Lucy H. Koh

STIPULATION AND [PROPOSED] ORDER CONTINUING SEPTEMBER 12, 2012 CASE MANAGEMENT CONFERENCE

Pursuant to Civil Local Rules 6-2 and 16-2(e), Plaintiff Chris Werdebaugh, on 20 behalf of himself and all others similarly situated, and Defendant Blue Diamond Growers 21 ("Blue Diamond"), through their undersigned counsel, hereby stipulate as follows: 22 WHEREAS, Blue Diamond was served with the summons and plaintiff's complaint 23 (the "Complaint") on June 28, 2012; 24 WHEREAS, pursuant to the parties' two prior stipulations, the current deadline for 25 Blue Diamond to answer or otherwise respond to the Complaint is September 4, 2012; 26 WHEREAS, pursuant to Federal Rule of Civil Procedure 26, the current deadline 27 for the parties to submit their Joint Case Management Statement and to exchange initial 28 disclosures is September 5, 2012; 4693783.1

WHEREAS, the initial case management conference is currently scheduled for 2 September 12, 2012 at 2:00 p.m.; 3

WHEREAS, given that Blue Diamond's responsive pleading is due just one day 4 before the parties' Joint Case Management Statement is due, the parties agree that 5 additional time is needed to meet and confer to prepare their Joint Case Management 6

Statement, to prepare their initial disclosures, and to otherwise prepare for the initial case 7 management conference; 8

WHEREAS, the date of the initial case management conference has not 9 previously been adjusted; 10

THEREFORE, the parties stipulate and agree, and respectfully request the Court 11 to order, as follows: 12

The initial case management conference is continued to October 24, 2012 at 2:00 13 p.m. All related deadlines, including those deadlines for completing the 26(f) conference, 14 the Joint Case Management Statement, and initial disclosures, are extended accordingly. 15 16

DATED: August 24, 2012 HANSON BRIDGETT LLP By: /S/ Megan Oliver Thompson*fn1 LAWRENCE M. CIRELLI SUSAN G. O'NEILL MEGAN OLIVER THOMPSON GEOFFREY R. PITTMAN Attorneys for Blue Diamond Growers

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED


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