Filed: Jul. 16, 2019
Latest Update: Jul. 16, 2019
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION FOR CLASS CERTIFICATION HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Beatrice Parker ("Plaintiff") and Defendant Cherne Contracting Corporation ("Defendant") hereby stipulate to this request that the Court enter an order modifying the scheduling order (Dkt. # 36). RECITALS 1. On January 29, 2019, the Court granted in part and denied in part Defendant's Motion to Dismiss. (Dkt. No. 32.) 2. On May 14, 2019, the pa
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION FOR CLASS CERTIFICATION HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Beatrice Parker ("Plaintiff") and Defendant Cherne Contracting Corporation ("Defendant") hereby stipulate to this request that the Court enter an order modifying the scheduling order (Dkt. # 36). RECITALS 1. On January 29, 2019, the Court granted in part and denied in part Defendant's Motion to Dismiss. (Dkt. No. 32.) 2. On May 14, 2019, the par..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION FOR CLASS CERTIFICATION
HAYWOOD S. GILLIAM, JR., District Judge.
Plaintiff Beatrice Parker ("Plaintiff") and Defendant Cherne Contracting Corporation ("Defendant") hereby stipulate to this request that the Court enter an order modifying the scheduling order (Dkt. # 36).
RECITALS
1. On January 29, 2019, the Court granted in part and denied in part Defendant's Motion to Dismiss. (Dkt. No. 32.)
2. On May 14, 2019, the parties participated in a mediation session that did not resolve the case.
3. Plaintiff has issued written discovery and the parties have met and conferred over dates available to depose Defendant's persons most knowledgeable.
4. The earliest dates available for the persons most knowledgeable depositions are August 26-27, 2019 in Minneapolis, Minnesota.
5. Good cause exists for the modification of the scheduling order, and the modification request is brought in good faith and not for purposes of undue delay.
STIPULATION
The parties hereby jointly stipulate to a request for an order granting modifying the scheduling order as set forth in the table below:
Current Deadline Proposed Deadline
File Class Certification Motion October 11, 2019 January 10, 2020
File Class Cert Opposition November 11, 2019 February 7, 2020
File Class Cert Reply December 11, 2019 March 6, 2020
Hearing date and time January 9, 2020 at 2:00 p.m. April 23, 2020 at 2:00 p.m.
Dated: July 3, 2019 BAKER & McKENZIE LLP
By: /s/ Arthur J. Rooney
Arthur J. Rooney
Attorney for Defendant
CHERNE CONTRACTING CORPORATION
Dated: July 3, 2019 KELLER GROVER LLP
By: /s/ Eric A. Grover
Robert Spencer
Attorney for Plaintiff
BEATRICE PARKER
Signature Attestation
Pursuant to Local Rule 5-1(i)(3), I attest that concurrence in the filing of this document has been obtained from each of the above signatories.
Dated: July 3, 2019 KELLER GROVER LLP
By: /s/ Eric A. Grover
Robert Spencer
[PROPOSED] ORDER
Pursuant to the foregoing stipulation the scheduling order is modified as follows:
Current Deadline Continued Deadline
File Class Certification Motion October 11, 2019 January 10, 2020
File Class Cert Opposition November 11, 2019 February 7, 2020
File Class Cert Reply December 11, 2019 March 6, 2020
Hearing date and time January 9, 2020 at 2:00 p.m. April 23, 2020 at 2:00 p.m.
IT IS SO ORDERED.
