Opinion
Case No. C 11-01919 JSW Case No. C 11-02001 JSW Case No. C 11-02893 JSW Case No. C 11-02659 JSW Case No. C 11-03233 JSW
11-28-2011
KIMBERLY MAIN, an individual, on behalf of herself and all others similarly situated, Plaintiff, v. WAL-MART STORES, INC., and DOES 1 through 50, inclusive, Defendants. ROBIN NELSON, an individual, on behalf of v. WAL-MART STORES, INC., and DOES 1 through 50, inclusive, Defendants. MARYLYNN GRIKAVICIUS, an individual, on behalf of herself and all others similarly situated, Plaintiff, v. WAL-MART STORES, INC., and DOES 1 through 50, inclusive, Defendants. LOURDES R. LANDEROS, an individual, behalf of herself and all others similarly situated, Plaintiff, v. WAL-MART STORES, INC., and DOES 1 through 50, inclusive, Defendants. TINA BAUER, an individual, on behalf of herself and all others similarly situated, Plaintiff, v. WAL-MART STORES, INC., and DOES 1 through 50, inclusive, Defendants.
Abraham J. Colman Scott H. Jacobs Brandon W. Corbridge Attorneys for Defendant WAL-MART STORES, INC. PATTERSON LAW GROUP, APC James R. Patterson Matthew J. O'Connor Attorneys for Plaintiff Kimberly Main STONEBARGER LAW, APC Gene J. Stonebarger Richard D. Lambert Attorneys for Plaintiff Robin Nelson WESTRUP KLICK LLP Mark L. VanBuskirk R. Duane Westrup Attorneys for Plaintiff Grikavicius HOFFMAN & LAZEAR Chad A. Saunders Attorney for Plaintiff Lourdes R. Landeros MORRIS and ASSOCIATES Stephen B. Morris Attorney for Plaintiff Tina Bauer
Gene J. Stonebarger
Richard D. Lambert
STONEBARGER LAW
A Professional Corporation
Attorneys for Plaintiff Nelson and the Class
Abraham J. Colman
Scott H. Jacobs
Brandon W. Corbridge
REED SMITH LLP
Attorneys for Defendant
Additional Counsel Listed on Signature Page
JOINT STIPULATION AND [PROPOSED] ORDER RE CONSOLIDATION OF ACTIONS AND CONSOLIDATED COMPLAINT
Hon. Jeffrey S. White
Courtroom 11, 19th Floor
herself and all others similarly situated, Plaintiff,
Plaintiffs Kimberly Main, Robin Nelson, Marylynn Grikavicius, Lourdes R. Landeros, and Tina Bauer ("Plaintiffs") and defendant Wal-Mart Stores, 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 December 9, 2011.
RECITALS
WHEREAS, this Court has issued Orders relating each of the above-captioned cases (Main v. Wal-Mart Stores, Inc., Case No. C 11-01919; ECF Doc. Nos. 14, 17, 28, 29);
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;
WHEREAS, the parties agree that Plaintiffs should file a consolidated complaint; and
WHEREAS, Plaintiffs agree that Stonebarger Law, APC, and Westrup Klick LLP, shall serve as Co-Lead Plaintiffs' Counsel once the above-referenced actions are consolidated.
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, (2) Plaintiffs shall file a consolidated complaint on or before December 9, 2011, (3) Stonebarger Law, APC, and Westrup Klick LLP, shall serve as Co-Lead Plaintiffs' Counsel once the above-referenced actions are consolidated, whereby Co-Lead Plaintiffs' Counsel will be responsible for directing work to be performed by Plaintiffs' counsel on behalf of the putative class, for the preparation of any documents to be filed with the Court, and for communications with the Court and Defense Counsel, and (4) this stipulation shall not alter the time within which the parties shall make their initial disclosures or respond to discovery requests that were propounded prior to entry of the order made pursuant to this stipulation.
IT IS SO STIPULATED.
REED SMITH LLP
Abraham J. Colman
Scott H. Jacobs
Brandon W. Corbridge
Attorneys for Defendant
WAL-MART STORES, INC.
PATTERSON LAW GROUP, APC
James R. Patterson
Matthew J. O'Connor
Attorneys for Plaintiff Kimberly Main
STONEBARGER LAW, APC
Gene J. Stonebarger
Richard D. Lambert
Attorneys for Plaintiff Robin Nelson
WESTRUP KLICK LLP
Mark L. VanBuskirk
R. Duane Westrup
Attorneys for Plaintiff Grikavicius
HOFFMAN & LAZEAR
Chad A. Saunders
Attorney for Plaintiff Lourdes R. Landeros
MORRIS and ASSOCIATES
Stephen B. Morris
Attorney for Plaintiff Tina Bauer
[PROPOSED] ORDER
Based on the foregoing, and good cause appearing, It Is Hereby Ordered that: as case no. 11-01919 JSW
(1) the above-referenced actions shall be consolidated for all purposes, (2) Plaintiffs shall file a consolidated complaint on or before December 9, 2011, (3) Stonebarger Law, APC, and Westrup Klick LLP, shall serve as Co-Lead Plaintiffs' Counsel in the above-referenced consolidated actions, and shall be responsible for directing work to be performed by Plaintiffs' counsel on behalf of the putative class, for the preparation of any documents to be filed with the Court, and for communications with the Court and Defense Counsel, and (4) this stipulation shall not alter the time within which the parties shall make their initial disclosures or respond to discovery requests that were propounded prior to entry of this order.
IT IS SO ORDERED.
THE HONORABLE JEFFREY S. WHITE
UNITED STATES DISTRICT JUDGE