Filed: May 02, 2014
Latest Update: May 02, 2014
Summary: STIPULATION AND [PROPOSED] SCHEDULING ORDER VINCE CHHABRIA, District Judge. Plaintiff Erin Allen ("Plaintiff"), and Defendant ConAgra Foods, Inc. ("Defendant") hereby stipulate and agree as follows: WHEREAS, on January 3, 2014, the Court entered an Order setting the class certification briefing schedule and other case dates initially proposed by the parties; WHEREAS, on March 4, 2014, the Court entered a Stipulated Order Re: ESI protocol, which governs the ESI discovery protocol in t
Summary: STIPULATION AND [PROPOSED] SCHEDULING ORDER VINCE CHHABRIA, District Judge. Plaintiff Erin Allen ("Plaintiff"), and Defendant ConAgra Foods, Inc. ("Defendant") hereby stipulate and agree as follows: WHEREAS, on January 3, 2014, the Court entered an Order setting the class certification briefing schedule and other case dates initially proposed by the parties; WHEREAS, on March 4, 2014, the Court entered a Stipulated Order Re: ESI protocol, which governs the ESI discovery protocol in th..
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STIPULATION AND [PROPOSED] SCHEDULING ORDER
VINCE CHHABRIA, District Judge.
Plaintiff Erin Allen ("Plaintiff"), and Defendant ConAgra Foods, Inc. ("Defendant") hereby stipulate and agree as follows:
WHEREAS, on January 3, 2014, the Court entered an Order setting the class certification briefing schedule and other case dates initially proposed by the parties;
WHEREAS, on March 4, 2014, the Court entered a Stipulated Order Re: ESI protocol, which governs the ESI discovery protocol in this case;
WHEREAS, the parties have been diligently engaged in the ESI discovery process;
WHEREAS, Defendant has encountered technical difficulties in compiling and producing some of the ESI in response to Plaintiff's discovery requests;
WHEREAS, Plaintiff also sought to depose Defendant and Defendant's employees in or by May 2014, but relevant personnel were not reasonably available until June 2014; and
WHEREAS, the parties have met and conferred with each other regarding the foregoing scheduling issues, and in the interests of judicial economy, the parties seek entry of a Scheduling Order that continues and adjusts the current class certification briefing schedule and other case dates by six (6) weeks (with the certification hearing adjusted back an additional week in light of the Thanksgiving holiday).
NOW, THEREFORE, Plaintiff and Defendant agree and respectfully request that the Court continue and adjust the current case schedule as proposed below:
Event Proposed Date
Motion for Class Certification due August 11, 2014
Response to Class Certification October 10, 2014
Reply to Class Certification November 3, 2014
Hearing on Class Certification December 4, 2014 at 1:30 p.m.
Close of Fact Discovery March 30, 2015
Expert Disclosures due April 27, 2015
Rebuttal Expert Disclosures due May 27, 2015
Close of Expert Discovery June 26, 2015
Dispositive Motions due July 3, 2015
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
