Jeff Jonah v. Kimberly-Clark Corporation et al

Northern District of California, cand-4:2015-cv-03243

STIPULATION WITH PROPOSED ORDER re [63] MOTION for Leave to File a Consolidated Amended Complaint filed by Jeff Jonah.

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1 GUTRIDE SAFIER LLP ADAM J. GUTRIDE (State Bar No. 181446) 2 SETH A. SAFIER (State Bar No. 197427) MARIE A. MCCRARY (State Bar No. 262670) 3 KRISTEN SIMPLICIO (State Bar No. 263291) 100 Pine Street, Suite 1250 4 San Francisco, California 94111 Telephone: (415) 336-6545 5 Facsimile: (415) 449-6469 6 TYCKO & ZAVAREEI LLP HASSAN ZAVAREEI 7 ANDREW JONATHAN SILVER 1828 L Street, N.W., Suite 1000 8 Washington, DC 20036 Telephone: (202) 417-3658 9 SPANGENBERG SHIBLEY & LIBER LLP 10 STUART E. SCOTT 1001 Lakeside Avenue East, Suite 1700 11 Cleveland, OH 44114 Telephone: (216) 696-3232 12 Facsimile: (216) 696-3924 13 Attorneys for Plaintiffs 14 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 15 OAKLAND DIVISION 16 JEFF JONAH, individually, and on behalf of Case No. 15-cv-03243-PJH 17 himself, the general public, and those similarly situated, STIPULATION AND [PROPOSED] ORDER 18 REGARDING BRIEFING SCHEDULE Plaintiff, 19 v. 20 KIMBERLY-CLARK CORPORATION, ET 21 AL., 22 Defendants. 23 24 This Stipulation is entered into by Plaintiffs Jennifer Davidson and Jeff Jonah 25 (collectively "Plaintiffs"), and Defendant Kimberly-Clark Corporation, Kimberly-Clark 26 Worldwide, Inc., and Kimberly-Clark Global Sales LLC (collectively, "Defendants") by and 27 through their respective counsel; 28 STIPULATION AND [PROPOSED] ORDER REGARDING AMENDED COMPLAINT 1 WHEREAS, Davidson v. Kimberly-Clark Corporation, et al., Case No. 14-cv-01783-PJH 2 and Jonah v. Kimberly-Clark Corporation, et al., Case No. 15-cv-03243-PJH were deemed 3 related; 4 WHEREAS, on January 30, 2019, Plaintiffs filed their Motion for Leave to File a 5 Consolidated Amended Complaint and a Motion to Intervene (collectively the "Motions"), setting 6 a hearing date of March 13, 2019, Dkt. 63; 7 WHEREAS, on February 8, 2019, the parties agreed to modify the briefing schedule to 8 allow for more time to prepare their respective opposition and reply briefs, while preserving the 9 March 13, 2019 hearing date, Dkt. 64; 10 WHEREAS, pursuant to that stipulation and order, Defendants filed their oppositions on 11 February 18, 2019, Dkts. 66, and Plaintiffs' replies in support of their Motions were due February 12 27, 2019; 13 WHEREAS, because the parties have been addressing other matters pertaining to the case, 14 the parties have decided to continue the briefing and hearing date; 15 WHEREAS, the parties have agreed that Plaintiffs may file their replies to the Motions on 16 March 6 and that the hearing shall be continued to March 20, 2019 at 9:00 a.m. 17 WHEREAS, this is the second time a modification of the deadline with respect to this 18 briefing schedule; 19 WHEREAS, this stipulation is not for purposes of delay and is being made without 20 prejudice to any party's positions in the litigation; and 21 WHEREAS, this time modification will not have any impact on any other scheduled 22 dates; 23 NOW THEREFORE, THE PARTIES BY COUNSEL HEREBY STIPULATE that 24 Plaintiffs may file their replies to the Motions on March 6 and that the hearing shall be continued 25 to March 20, 2019 at 9:00 a.m. 26 27 SO STIPULATED 28 2 STIPULATION AND [PROPOSED] ORDER REGARDING AMENDED COMPLAINT 1 2 Dated: February 28, 2019 GUTRIDE SAFIER LLP 3 4 5 By: /s/ Kristen Simplicio Marie A. McCrary 6 Attorneys for Plaintiffs 7 8 DATED: February 28, 2019 SIDLEY AUSTIN LLP 9 10 By:/s/ Amy Lally Amy Lally 11 Attorneys for Defendants 12 13 IT IS SO ORDERED. 14 15 DATED: THE HONORABLE PHYLLIS J. HAMILTON 16 UNITED STATES DISTRICT JUDGE 17 18 ATTESTATION OF COMPLIANCE 19 I, Kristen Simplicio, am the ECF user whose ID and password are being used to file this 20 document. In compliance with section X(B) of General Order 45, I hereby attest that Amy Lally 21 concurred in this filing. 22 /s/ Kristen Simplicio 23 24 25 26 27 28 3 STIPULATION AND [PROPOSED] ORDER REGARDING AMENDED COMPLAINT