Filed: Dec. 04, 2015
Latest Update: Dec. 04, 2015
Summary: JOINT STIPULATION AND ORDER TO AMEND SCHEDULING ORDER HAYWOOD S. GILLIAM, Jr. , District Judge . Plaintiff Liza Gershman ("Plaintiff") and Defendant Bayer HealthCare, LLC ("Defendant") (collectively, the "Parties"), by and through their undersigned counsel, stipulate as follows: WHEREAS, the Court entered a Scheduling Order on June 5, 2015 (Doc. 61), setting certain deadlines in the case, including deadlines for the class certification submissions and a class certification hearing; WHEREA
Summary: JOINT STIPULATION AND ORDER TO AMEND SCHEDULING ORDER HAYWOOD S. GILLIAM, Jr. , District Judge . Plaintiff Liza Gershman ("Plaintiff") and Defendant Bayer HealthCare, LLC ("Defendant") (collectively, the "Parties"), by and through their undersigned counsel, stipulate as follows: WHEREAS, the Court entered a Scheduling Order on June 5, 2015 (Doc. 61), setting certain deadlines in the case, including deadlines for the class certification submissions and a class certification hearing; WHEREAS..
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JOINT STIPULATION AND ORDER TO AMEND SCHEDULING ORDER
HAYWOOD S. GILLIAM, Jr., District Judge.
Plaintiff Liza Gershman ("Plaintiff") and Defendant Bayer HealthCare, LLC ("Defendant") (collectively, the "Parties"), by and through their undersigned counsel, stipulate as follows:
WHEREAS, the Court entered a Scheduling Order on June 5, 2015 (Doc. 61), setting certain deadlines in the case, including deadlines for the class certification submissions and a class certification hearing;
WHEREAS, the discovery process in this case has been ongoing but at a slower pace than initially expected, in part as a result of the time necessary to undertake and complete the electronic document review;
WHEREAS, the Parties believe that additional time (approximately three months) is necessary to complete Defendant's document production, to allow Plaintiffs to review the production in its entirety, and for both Parties to prepare for and take depositions of witnesses (including the plaintiffs) for purposes of supporting and opposing class certification;
WHEREAS, the Parties agree that because additional time is needed for purposes of addressing class certification, adjustments are needed to the deadlines set forth in the Court's June 5, 2015 Scheduling Order;
WHEREAS, the Parties met and conferred, and have agreed to a 90-day extension regarding class certification and related deadlines.
IT IS HEREBY STIPULATED by the Parties, by and through their counsel, subject to the Court's approval, that the Scheduling Order dated June 5, 2015 be amended as follows:
Event Date
Deadline to File Motion for Class Certification March 9, 2016
Deadline to File Opposition to Motion for Class May 11, 2016
Certification
Deadline to File Reply in Support of Motion for June 22, 2016
Class Certification
Last Day to Hear Motion for Class Certification July 18, 2016
PURSUANT TO STIPULATION, IT IS SO ORDERED EXCEPT THAT THE LAST DAY TO HEAR MOTION FOR CLASS CERTIFICATION IS JULY 21, 2016.
CERTIFICATION OF APPROVAL OF CONTENT
Counsel for Plaintiff, Patricia Syverson, certifies that, pursuant to Section 2.f.4 of the Court's CM/ECF Administrative Policies, Defendant's Counsel, Kara McCall, has reviewed the contents of the foregoing, and authorized placement of her electronic signature on this document. onnett, Fairbourn, Friedman & Balint, P.C.,
