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