Filed: Jul. 29, 2019
Latest Update: Jul. 29, 2019
Summary: STIPULATION AND ORDER EXTENDING DEADLINES FOR PLAINTIFFS TO FILE MOTION FOR CLASS CERTIFICATION AND EXPERT DISCLOSURE DEADLINES CARL W. HOFFMAN , Magistrate Judge . Plaintiffs and Defendants HEREBY STIPULATE AND AGREE, by and through their respective counsel, as to the following: 1. Per the Discovery Plan and Scheduling Order, Plaintiffs' Motion for Class Certification is currently due for filing on or before July 29, 2019. See Doc. 38, Discovery Plan and Scheduling Order, p. 5, Para. 2.b
Summary: STIPULATION AND ORDER EXTENDING DEADLINES FOR PLAINTIFFS TO FILE MOTION FOR CLASS CERTIFICATION AND EXPERT DISCLOSURE DEADLINES CARL W. HOFFMAN , Magistrate Judge . Plaintiffs and Defendants HEREBY STIPULATE AND AGREE, by and through their respective counsel, as to the following: 1. Per the Discovery Plan and Scheduling Order, Plaintiffs' Motion for Class Certification is currently due for filing on or before July 29, 2019. See Doc. 38, Discovery Plan and Scheduling Order, p. 5, Para. 2.b...
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STIPULATION AND ORDER EXTENDING DEADLINES FOR PLAINTIFFS TO FILE MOTION FOR CLASS CERTIFICATION AND EXPERT DISCLOSURE DEADLINES
CARL W. HOFFMAN, Magistrate Judge.
Plaintiffs and Defendants HEREBY STIPULATE AND AGREE, by and through their respective counsel, as to the following:
1. Per the Discovery Plan and Scheduling Order, Plaintiffs' Motion for Class Certification is currently due for filing on or before July 29, 2019. See Doc. 38, Discovery Plan and Scheduling Order, p. 5, Para. 2.b.9.
2. Plaintiffs' counsel have advised Defendants' counsel that they have scheduling conflicts, including the fact that lead counsel for Plaintiff will be out of state related to another federal action on July 28 and 29, 2019, which will create difficulty with the completion and filing of Plaintiffs' Motion for Class Certification and related filings in support of Plaintiffs' Motion.
3. In addition, the Court has recently entered an Stipulated Protective Order governing the exchange and use of confidential documents (see Doc. 48), and Plaintiffs have indicated that they anticipate that some documents produced by Defendants following entry of the Stipulated Agreed Protective Order may be used in conjunction with Plaintiffs' Motion for Class Certification.
4. A brief, one-week extension will not affect the ultimate disposition of this case or the remaining deadlines contained in the Discovery Plan and Scheduling Order.
5. Defendants do not oppose Plaintiffs' request for a brief one-week extension.
6. Per the Discovery Plan and Scheduling Order, the parties are required to exchange expert disclosures by July 29, 2019 and rebuttal expert disclosures by August 28, 2019. Given the current status of the case, including Plaintiffs' pending Motion for Conditional Certification related to the FLSA claims of Plaintiffs and putative collective class members, the parties are unable to complete expert disclosures at this time. The parties request that the Court extend the expert disclosure deadline to August 27, 2019, and the rebuttal expert disclosure deadline to September 27, 2019.
7. Based on the foregoing, Defendants stipulate to the brief one-week extension from July 29, 2019 to August 5, 2019 for Plaintiffs' request for an order extending the deadline for Plaintiffs to file their Motion for Class Certification from July 29, 2019 to August 5, 2019, and the parties stipulate and request that the Court extend the expert disclosure deadline from July 29, 2019, to August 27, 2019, and the rebuttal expert disclosure deadline from August 28, 2019, to September 27, 2019.
IT IS SO STIPULATED.
DICKINSON WRIGHT PLLC LEWIS ROCA ROTHGERBER CHRISTIE LLP
/s/ Martin D. Holmes /s/ Alison M. Hamer
MICHAEL N. FEDER HOWARD E. COLE
Nevada Bar No. 7332 Nevada Bar No. 4950
8363 West Sunset Road, Suite 200 JENNIFER K. HOSTETLER
Las Vegas, NV 89113 Nevada Bar No. 11994
3993 Howard Hughes Pkwy, Suite 600
MARTIN D. HOLMES Las Vegas, NV 89169-5996
(Admitted Pro Hac Vice)
Tennessee Bar No. 012122 KIRSTIN E. MULLER
PETER F. KLETT (Admitted Pro Hac Vice)
(Admitted Pro Hac Vice) California Bar No. 186373
Tennessee Bar No. 012688 ALISON M. HAMER
Fifth Third Center, Suite 800 (Admitted Pro Hac Vice)
424 Church Street California Bar No. 258281
Nashville, TN 37219 BENJAMIN J. TREGER
(Admitted Pro Hac Vice)
Attorneys for Plaintiffs, California Bar No. 285283
Putative Collective Class Members Hirschfeld Kramer LLP
and Putative Hawaii Class Members 233 Wilshire Boulevard, Suite 600
Santa Monica, California 90401
Attorneys for Defendants
IT IS SO ORDERED.
