Free Stipulation - District Court of California - California

Case 4:07-cv-04980-CW

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Filed 08/05/2008

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1 Andrew J. Ogilvie (SBN 57932)

Kemnitzer, Anderson, Barron, Ogilvie & Brewer, LLP 445 Bush Street, 6th Floor 3 San Francisco, CA 94108 Ph: (415) 861-2265 4 Fax: (415) 861-3151 5 [email protected]
2 Pro hac vice 6 Robert S. Sola Robert S. Sola, P.C. 7 8835 S.W. Canyon Lane, Suite 130 Portland, Oregon 97225 8 Ph: (503) 295-6880 9 Fax: (503) 291-9172 [email protected] 10 11 12 13 14 15 16 17 18 19

Attorneys for Plaintiff Emelia M. Pasternak

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

EMELIA M PASTERNAK, Plaintiff, v.

20 TRANS UNION, LLC, et al, 21 22 23

Defendants.

) ) ) ) ) ) ) ) ) )

Case No. 4:07-cv-04980-CW (BZ)

JOINT REVISED REQUEST AND PROPOSED ORDER EXTENDING DATES FOR COMPLETING DISCOVERY AND FILING CASE DISPOSITIVE MOTIONS

The parties through their respective counsel have had extensive discussions

24 concerning the completion of the depositions of the parties. Currently the date set for 25 completion of fact discovery is September 5, 2008. Case Management Order, Dkt. 26 #62. The Court has scheduled October 9, 2008 as the last day for hearing case 27 dispositive motions and for the next case management conference. Id. 28 Pasternak v. Trans Union, LLC, ND Cal., case no. 4:07-cv-04980 CW (BZ)
Joint Revised Request and Proposed Order 1

Case 4:07-cv-04980-CW

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1

Due to the unavailability of witnesses and counsel at various times during the

2 next six weeks, counsel have been unable to schedule depositions of the parties in a 3 way that will permit the parties to complete the discovery they need within that 4 timeframe and accommodate the legitimate needs of all parties. 5

The parties and their respective counsel agree that a two week extension of the

6 deadlines for the completion of the depositions of all the parties and for the filing of 7 case dispositive motions would enable them to resolve these scheduling problems 8 without necessitating the Court's involvement. The parties jointly request that the 9 Court enter an order extending the deadline for the completion of depositions of the 10 parties to September 19, 2008, and that it also extend the deadline for hearing case 11 dispositive motions and the date of the next case management conference to November 12 13, 2008. 13 August 5, 2008. 14 KEMNITZER, ANDERSON, BARRON OGILVIE & BREWER LLP 15

ROBERT S. SOLA, P.C. /s/ Andrew J. Ogilvie Attorneys for Plaintiff Emelia M. Pasternak

16 By 17 18 19 20 21 22 23 24 JONES DAY 25 26 27

REED SMITH By /s/ Veronica Kuiumdjian Attorneys for Defendant Capital One Bank

By

/s/ Lucinda Andrew Attorneys for Defendant Experian Information Solutions, Inc.
2

28 Pasternak v. Trans Union, LLC, ND Cal., case no. 4:07-cv-04980 CW (BZ)
Joint Revised Request and Proposed Order

Case 4:07-cv-04980-CW

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1 KING & SPALDING 2 3 4

By

/s/ Cara Hergenroether Attorneys for Defendant Equifax Information Services LLC

5 MUSICK, PEELER & GARRETT LLP 6 7 8 9 10 [Proposed] ORDER 11

By

/s/ Donald E. Bradley Attorneys for Defendant Trans Union LLC

Pursuant to the stipulation of the parties by their respective counsel, the Court

12 hereby ORDERS that the discovery deadline for the completion of the depositions of the 13 parties is extended to September 19, 2008 and the last day for hearing case dispositive 14 motions is extended to 2 pm on November 13, 2008. The next case management 15 conference shall be 2 pm on November 13, 2008. 16 Dated: August 13, 2008 17 18 19 20 21 22 23 24 25 26 27 28 Pasternak v. Trans Union, LLC, ND Cal., case no. 4:07-cv-04980 CW (BZ)
Joint Revised Request and Proposed Order 3

Claudia Wilken United States District Judge