Opinion
BLUMENTHAL, NORDREHAUG & BHOWMIK, Norman B. Blumenthal, Kyle R. Nordrehaug, Aparajit Bhowmik, Piya Mukherjee, La Jolla, CA, Attorneys for Plaintiff.
FORD & HARRISON LLP, David L. Cheng, Los Angeles, CA, Attorneys for Defendants.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CLASS CERTIFICATION FILING DATES
GARLAND E. BURRELL, Jr., Senior District Judge.
Plaintiff CHRISTINA CULLEY ("Plaintiff") and Defendants LINCARE INC. and ALPHA RESPIRATORY INC. ("Defendants"), by and through their respective counsel, hereby stipulate as follows:
WHEREAS, the Court initially set the following Class Certification schedule:
• Plaintiff's deadline to file motion: September 28, 2015
• Defendant's deadline to file opposition: November 2, 2015
• Plaintiff's deadline to file reply: November 16, 2015
• Hearing re: Class Certification Motion: November 30, 2015
WHEREAS, the Parties are awaiting an order by the Magistrate Judge requiring Defendant Alpha Respiratory Inc. ("Defendant") to produce documents and records which Plaintiff will utilize for purposes of the class certification motion;
WHEREAS, the Parties have conferred and believe that a continuance of the briefing schedule for the motion for class certification is warranted to provide a sufficient amount of time for Defendant to produce the records and for Plaintiff to thereafter analyze the records and information;
WHEREAS, this is the first request for a continuance by either Party;
NOW, THEREFORE, the parties hereby stipulate and agree, and respectfully request the Court to order that the briefing schedule for the motion for class certification be continued to the following dates:
• Plaintiff's deadline to file motion: December 18, 2015
• Defendant's deadline to file opposition: February 5, 2016
• Plaintiff's deadline to file reply: February 26, 2016
• Hearing re: Class Certification Motion: March 21, 2016
IT IS SO STIPULATED.
IT IS SO ORDERED.