Opinion
Coordinated Case No. 11-cv-00893-SI Case No. 11-cv-01588-SI Case No. 11-cv-02451 SI
11-11-2011
DUSTIN GORMLEY, individually and on behalf of all others similarly situated, Plaintiffs, v. NIKE, INC., an Oregon corporation, Defendant. ERIKA MCCARTNEY, on behalf of herself and all others similarly situated, Plaintiff, v. NIKE, Inc., an Oregon corporation; and DOES 2 through 20, Defendants. KRISTEN L. HARTMAN, an individual, on behalf of herself and all others similarly situated, Plaintiff, v. NIKE USA, INC., an Oregon Corporation; NIKE RETAIL SERVICES, INC., an Oregon Corporation, and DOES 1 through 50, inclusive, Defendants.
COOLEY LLP MICHELLE C. DOOLIN JENNIFER M. FRENCH BEATRIZ MEJIA MATTHEW M. BROWN Beatriz Mejia Attorneys for Defendants NIKE, INC., NIKE USA, INC., AND NIKE RETAIL SERVICES, INC. HOFFMAN & LAZEAR H. TIM HOFFMAN ARTHUR W. LAZEAR CHAD A. SAUNDERS Chad A. Saunders Attorneys for Plaintiff DUSTIN GORMLEY PACIFIC JUSTICE CENTER ROBERT B. HANCOCK MELVIN B. PEARLSTON Robert B. Hancock Attorneys for Plaintiff ERIKA MCCARTNEY FINEMAN & ASSOCIATES NEIL B. FINEMAN Neil B. Fineman Attorneys for Plaintiff ERIKA MCCARTNEY STONEBARGER LAW, APC GENE J. STONEBARGER RICHARD D. LAMBERT Gene J. Stonebarger Attorneys for Plaintiff KRISTEN L. HARTMAN
Gene J. Stonebarger, State Bar No. 209461
Richard D. Lambert, State Bar No. 251148
STONEBARGER LAW
A Professional Corporation
Attorneys for Plaintiff Kristen L. Hartman
Additional Attorneys Listed on Signature Page
JOINT STIPULATION AND [PROPOSED]]
ORDER RE CONSOLIDATION OF ACTION AND CONSOLIDATED COMPLAINT
Hon. Susan Illston
Plaintiffs Dustin Gormley, Erika McCartney, and Kristen L. Hartman ("plaintiffs") and defendants Nike, Inc., Nike USA, Inc., and Nike Retail Services, Inc., by and through their respective counsel, jointly submit the following Stipulation regarding consolidation of the above-referenced actions for all purposes and the filing of plaintiffs' consolidated complaint on or before November 11, 2011.
RECITALS
WHEREAS, on July 20, 2011, Judge Illston issued an order coordinating the above-captioned related cases (Gormley v. Nike, Inc., Coordinated Case No. 11-cv-00893-SI, ECF No. 31); and
WHEREAS, the parties agree that the above-referenced actions should be consolidated for all purposes because it will promote the interests of judicial economy and efficiency; and WHEREAS, the parties agree that plaintiffs should file a consolidated complaint;
STIPULATION
NOW, THEREFORE, IT IS STIPULATED AND AGREED, by the parties, through their respective counsel of record, that (1) the above-referenced actions shall be consolidated for all purposes, and (2) that plaintiffs shall file a consolidated complaint on or before November 11, 2011.
IT IS SO STIPULATED.
COOLEY LLP
MICHELLE C. DOOLIN
JENNIFER M. FRENCH
BEATRIZ MEJIA
MATTHEW M. BROWN
Beatriz Mejia
Attorneys for Defendants
NIKE, INC., NIKE USA, INC., AND NIKE
RETAIL SERVICES, INC.
HOFFMAN & LAZEAR
H. TIM HOFFMAN
ARTHUR W. LAZEAR
CHAD A. SAUNDERS
Chad A. Saunders
Attorneys for Plaintiff
DUSTIN GORMLEY
PACIFIC JUSTICE CENTER
ROBERT B. HANCOCK
MELVIN B. PEARLSTON
Robert B. Hancock
Attorneys for Plaintiff
ERIKA MCCARTNEY
FINEMAN & ASSOCIATES
NEIL B. FINEMAN
Neil B. Fineman
Attorneys for Plaintiff
ERIKA MCCARTNEY
STONEBARGER LAW, APC
GENE J. STONEBARGER
RICHARD D. LAMBERT
Gene J. Stonebarger
Attorneys for Plaintiff
KRISTEN L. HARTMAN
FILER'S ATTESTATION
Pursuant to General Order No. 45, Section X, Subparagraph B, the undersigned attests that all parties have concurred in the filing of this Joint Stipulation and [Proposed] Order re Consolidation of Action and Consolidated Complaint.
STONEBARGER LAW, APC
GENE J. STONEBARGER
RICHARD D. LAMBERT
Gene J. Stonebarger
Attorneys for Plaintiff
KRISTEN L. HARTMAN
IT IS SO ORDERED.
The Honorable Susan Illston
United States District Judge
Related Case 11-1588 and 11-2451 shall be administratively closed.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on November 11, 2011, the foregoing JOINT STIPULATION AND [PROPOSED] ORDER RE CONSOLIDATION OF ACTION AND CONSOLIDATED COMPLAINT was filed electronically with the Clerk of the Court to be served by operation of the Court's CM/ECF electronic filing system to all counsel of record.
Jamie Mendez