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Lazarin v. Pro Unlimited, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN JOSE DIVISION
Nov 23, 2011
Case No. 5:11-CV-03609-HRL (N.D. Cal. Nov. 23, 2011)

Opinion

Case No. 5:11-CV-03609-HRL

11-23-2011

MICHAEL LAZARIN, STEPHEN KOHLER, and PAUL CAPANO, individually and on behalf of other members of the general public similarly situated, and as aggrieved employees pursuant to the Private Attorneys General Act ("PAGA") Plaintiffs, v. PRO UNLIMITED, INC., JUNIPER NETWORKS, INC., JUNIPER NETWORKS HOLDINGS INTERNATIONAL, INC., and JUNIPER NETWORKS (US), INC. Defendants.

JACKSON LEWIS LLP CARY G. PALMER, Cal. Bar No. 186601 HEATH A. HAVEY, Cal Bar No, 244087 Attorneys for Defendant PrO Unlimited, Inc.


JACKSON LEWIS LLP

CARY G. PALMER, Cal. Bar No. 186601

HEATH A. HAVEY, Cal Bar No, 244087

Attorneys for Defendant

PrO Unlimited, Inc.

JOINT STIPULATION TO EXTEND TIME FOR RULE 26(f) REPORT, INITIAL DISCLOSURES AND CMC CONFERENCE AND [PROPOSED] ORDER

TO THE HONORABLE COURT AND TO ALL PARTIES AND COUNSEL: WHEREFORE, pursuant to Federal Rule of Civil Procedure 16(b)(4), and for good cause, plaintiffs Michael Lazarin, Stephen Kohler and Paul Capano ("Plaintiffs"), and defendants PrO Unlimited, Inc. ("PrO"), Juniper Networks, Inc., Juniper Network Holdings International, Inc., and Juniper Networks (US), Inc., by and through their respective attorneys of record, hereby jointly stipulate and request the Court to vacate the dates set forth in the Order granting the Joint Stipulation to Extend Time for Filing Rule 26(f) Report, Initial Disclosures, and CMC Conference, filed on September 28, 2011, and in the Clerk's Notice of Continuing Case Management Conference filed on November 14, 2011, and to continue such dates as set forth in the stipulation below. Plaintiffs and Defendants currently are exploring the prospects for possible early settlement and/or mediation. Last week Defendant PrO voluntarily produced data and documents to facilitate potential settlement and/or mediation. Defendant Juniper Network, Inc. ("Juniper") made its first appearance on November 7, 2011; on November 22, 2011, the parties filed a stipulation and order to dismiss the named Defendants Juniper Networks Holdings International, Inc. and Juniper Networks (US). The parties respectfully request additional time to focus on streamlining the litigation.

WHEREFORE, the parties hereby jointly stipulate and request as follows:

1. The current deadline of November 22, 2011, to file the Rule 26(f) Report, to complete initial disclosures, to state objections in the Rule 26(f) Report, and to file a Case Management Statement per the Court's Notice Continuing Case Management Conference filed on November 14, 2011, be continued to January 17, 2012;
2. The current deadline of November 22, 2011, to file a joint case management statement, be continued to January 17, 2012; and
3. The Initial Case Management Conference presently set for November 29, 2011, be continued to January 24, 2012.

IT IS SO STIPULATED

RUKIN HYLAND DORIA & TINDALL LLP

Peter Rukin

Attorneys for Plaintiffs

JACKSON LEWIS LLP

Cary G. Palmer

Attorneys for Defendant

PrO Unlimited, Inc.

ALLEN MATKINS LECK GAMBLE MALLORY & NATSIS LLP

Baldwin J. Lee

Attorneys for Defendant

Juniper Networks, Inc., Juniper Network

Holdings, International, Inc. and Juniper

Networks (US), Inc.

FOR GOOD CAUSE, IT IS HEREBY ORDERED AS FOLLOWS:

1. The current deadline of November 22, 2011, to file the Rule 26(f) Report, to complete initial disclosures, to state objections in the Rule 26(f) Report, and to file a Case Management Statement be continued to January 17, 2012;
2. The current deadline of November 22, 2011, to file a joint case management statement, be continued to January 17, 2012; and
3. The Initial Case Management Conference presently set for November 29, 2011, be continued to January 24, 2012.

HONORABLE HOWARD R. LLOYD

MAGISTRATE JUDGE OF THE

UNITED STATES DISTRICT COURT


Summaries of

Lazarin v. Pro Unlimited, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN JOSE DIVISION
Nov 23, 2011
Case No. 5:11-CV-03609-HRL (N.D. Cal. Nov. 23, 2011)
Case details for

Lazarin v. Pro Unlimited, Inc.

Case Details

Full title:MICHAEL LAZARIN, STEPHEN KOHLER, and PAUL CAPANO, individually and on…

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN JOSE DIVISION

Date published: Nov 23, 2011

Citations

Case No. 5:11-CV-03609-HRL (N.D. Cal. Nov. 23, 2011)