Johnson v. Glock, Inc. et al, No. 3:2020cv08807 - Document 154 (N.D. Cal. 2023)
Court Description: ORDER granting 153 Stipulation to Reset Deadlines as to 148 MOTION for Class Certification. Responses due by 2/23/2024. Replies due by 5/23/2024. Motion Hearing set for 6/12/2024 02:00 PM via Videoconference before Judge William H. Orrick. Signed by Judge William H. Orrick on 11/27/2023. (jmd, COURT STAFF) (Filed on 11/27/2023)
Download PDF
<![CDATA[
1 2 3 4 5 KIESEL LAW LLP Paul R. Kiesel, State Bar No. 119854 Jeffrey A. Koncius, State Bar No. 189803 8648 Wilshire Boulevard Beverly Hills, California 90211-2910 Tel: 310-854-4444 Fax: 310-854-0812 Email: kiesel@kiesel.law Email: koncius@kiesel.law 6 7 Attorneys for Plaintiff Steven C. Johnson 8 Paul G. Cereghini (SBN 148016) Lauren O. Miller (SBN 279448) BOWMAN AND BROOKE LLP 1741 Technology Drive, Suite 200 San Jose, CA 95110 Telephone: (408) 279-5393 Facsimile: (408) 279-5845 paul.cereghini@bowmanandbrooke.com lauren.miller@bowmanandbrooke.com carissa.casolari@bowmanandbrooke.com 9 10 11 12 13 14 LEWIS AND LEWIS TRIAL LAWYERS, PLC Robert K. Lewis (AZ SBN 016625) Pro Hac Vice Amy M. Lewis (AZ SBN 027201) Pro Hac Vice Scottsdale, AZ 85262 Tel: (602) 889-6666 Email: Rob@LewisLawFirm.com Email: Amy@LewisLawFirm.com Christopher Renzulli (Pro Hac Vice) John F. Renzulli (Pro Hac Vice) Howard B. Schilsky (Pro Hac Vice) RENZULLI LAW FIRM, LLP One North Broadway, Suite 1005 White Plains, NY 10601 Telephone: (914) 285-0700 Facsimile: (914) 285-1213 jrenzulli@renzullilaw.com crenzulli@renzullilaw.com hschilsky@renzullilaw.com Attorneys for Defendants Glock, Inc. and Glock Ges.m.b.H. 15 16 17 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION 18 19 20 21 22 23 24 25 26 27 28 29 30 31 STEVEN C. JOHNSON, an individual, on ) behalf of himself and all others similarly ) ) situated, ) Plaintiff, ) vs. ) GLOCK, INC., a Georgia Corporation; ) GLOCK Ges.m.b.H., an Austrian entity; ) JOHN and JANE DOES I through V; ) ABC CORPORATIONS I-X, XYZ ) PARTNERSHIPS, SOLE ) PROPRIETORSHIPS and/or JOINT ) VENTURES I-X, GUN COMPONENT ) MANUFACTURERS I-V ) ) Defendants. CASE NO.: 3:20-cv-08807-WHO JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS CERTIFICATION BRIEFING SCHEDULE CASE NO.: 3:20-cv-08807-WHO JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS CERTIFICATION BRIEFING SCHEDULE 1 Plaintiff STEVEN C. JOHNSON (“Plaintiff”) and Defendants GLOCK, INC., and 2 GLOCK Ges.m.b.H. (“Defendants,” and together with Plaintiff, the “Parties”), by and 3 through their counsel of record, and pursuant to Civil L.R. 6-2 and Rule 29 of the Federal 4 Rules of Civil Procedure, hereby stipulate and jointly move to continue the class 5 certification briefing schedule as described below. 6 WHEREAS, Plaintiff filed his Motion for Class Certification on October 12, 2023. 7 WHEREAS, Defendants’ opposition is due on December 12, 2023, and Plaintiff’s 8 reply is due on February 12, 2024. (ECF No. 99). The hearing on Plaintiff’s Motion for 9 Class Certification is currently scheduled for February 28, 2024. Id. 10 WHEREAS, the Court has previously approved two extensions of the deadline for 11 Plaintiff to file his Motion for Class Certification (and associated deadlines). (ECF Nos. 12 93-94; 98-99). 13 WHEREAS, the Parties are requesting an extension of the deadline for Defendants’ 14 opposition to Plaintiff’s Motion for Class Certification (and associated deadlines) due to 15 the following circumstances: (1) 16 Expert Depositions. Plaintiff’s Motion for Class Certification relies upon an 17 extensive record and four expert reports. The expert reports alone total a combined 318 18 pages. The remaining 39 separate exhibits are thousands of pages and include some 19 documents Defendants had not previously seen. Based on Plaintiff’s submission, 20 Defendants are contemplating the appropriate response to oppose Plaintiff’s Motion for 21 Class Certification. Preliminarily, the Parties are attempting to schedule depositions of 22 Plaintiff’s proposed experts but have encountered timing issues that affect Defendants’ 23 ability to conduct depositions before their opposition is due. For example, one of Plaintiff’s 24 experts will not be available for a deposition until mid-January and the Parties are still 25 attempting to coordinate dates for the depositions of Plaintiff’s other three experts in 26 December and/or January (if necessary). In addition to complications with coordinating 27 everyone’s various schedules, upcoming holidays have become a factor for scheduling. 28 /// 29 CASE NO.: 3:20-cv-08807-WHO JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS CERTIFICATION BRIEFING SCHEDULE 30 31 1 The Parties agree that additional time is needed to conduct depositions of Plaintiff’s experts 2 with sufficient time for Defendants to prepare their opposition to class certification. 3 (2) Defendants’ Expert Reports. Defendants’ experts also need additional time 4 to prepare their reports as they intend to rely, at least in part, on testimony of Plaintiff’s 5 experts. Considering the voluminous record, Defendants believe additional time is needed 6 for Defendants’ experts to prepare full and complete responsive reports. 7 (3) Additional Discovery. Defendants served a second set of requests for 8 production and interrogatories on Plaintiff following Plaintiff’s deposition that was 9 conducted on September 7, 2023. Defendants agreed to extend the time for Plaintiff to 10 respond to the discovery until November 30. Plaintiff’s responses, however, are necessary 11 for Defendants to prepare their opposition to class certification and, therefore, additional 12 time is needed to receive and review Plaintiff’s supplemental discovery responses before 13 the deadline for Defendants to file their opposition. (4) 14 Commensurate Extension for Plaintiff. Considering the foregoing, Plaintiff 15 is also requesting an extension of time for filing his reply. To the extent Plaintiff seeks 16 depositions of Defendants’ experts, the Parties anticipate that similar scheduling issues 17 may arise and believe it would be prudent to allow for some flexibility in scheduling. 18 Plaintiff also recently served a third set of requests for production and interrogatories, 19 including 86 additional requests for production, and a second set of 63 additional requests 20 for admission on Defendants. Plaintiff has agreed to extend the time for Defendants to 21 respond while the parties meet and confer regarding the scope of this discovery. The Parties 22 agree that additional time is warranted to the extent Plaintiff believes the additional 23 discovery is needed for his reply. WHEREAS, the Parties have met and conferred, and stipulate to mutually extend 24 25 the remaining class certification deadlines as follows: 1. The new deadline for Defendants to file an Opposition to Plaintiff’s Motion 26 for Class Certification is February 23, 2024. 27 28 /// 29 CASE NO.: 3:20-cv-08807-WHO JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS CERTIFICATION BRIEFING SCHEDULE 30 31 1 2 3 4 2. The new deadline for Plaintiff to file his Reply in support of his Motion for Class Certification is May 23, 2024. 3. The new hearing date on Plaintiff’s Motion for Class Certification is June 5, 2024, at 2:00 p.m. PST, or as soon thereafter as counsel may be heard. 5 IT IS SO STIPULATED. 6 Respectfully submitted, 7 8 9 10 11 12 13 14 15 16 17 18 19 Dated: November 27, 2023 /s/ Robert Lewis__________ LEWIS LAW FIRM, PLC Robert K. Lewis, Pro Hac Vice Amy M. Lewis, Pro Hac Vice 2302 N. 3rd Street Phoenix, Arizona 85004 Tel: (602) 889-6666 Fax: (602) 252-1446 Email: rob@lewislawfirm.com Email: amy@lewislawfirm.com Paul R. Kiesel, State Bar No. 119854 kiesel@kiesel.law Jeffrey A. Koncius, State Bar No. 189803 koncius@kiesel.law KIESEL LAW LLP 8648 Wilshire Boulevard Beverly Hills, California 90211-2910 Tel: 310-854-4444 Fax: 310-854-0812 25 Nicholas Panayotopoulos, Pro Hac Vice npanayo@wwhgd.com Gary J. Toman, Pro Hac Vice gtoman@wwhgd.com Alexander Heydemann, Pro Hac Vice aheydemann@wwhgd.com WEINBERG WHEELER HUDGINS GUNN & DIAL LLC 3344 Peachtree Road, NE Atlanta, Georgia 30326 Tel: 404-876-2700 26 Attorneys for Plaintiff 20 21 22 23 24 27 28 29 30 31 CASE NO.: 3:20-cv-08807-WHO JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS CERTIFICATION BRIEFING SCHEDULE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Dated: November 27, 2023 /s/ Howard B. Schilsky John F. Renzulli (Pro Hac Vice) Christopher Renzulli (Pro Hac Vice) Howard B. Schilsky (Pro Hac Vice) RENZULLI LAW FIRM, LLP One North Broadway, Suite 1005 White Plains, NY 10601 Telephone: (914) 285-0700 Facsimile: (914) 285-1213 jrenzulli@renzullilaw.com crenzulli@renzullilaw.com hschilsky@renzullilaw.com Paul G. Cereghini (SBN 148016) Lauren O. Miller (SBN 279448) BOWMAN AND BROOKE LLP 1741 Technology Drive, Suite 200 San Jose, CA 95110 Telephone: (408) 279-5393 Facsimile: (408) 279-5845 paul.cereghini@bowmanandbrooke.com lauren.miller@bowmanandbrooke.com Carissa Casolari (SBN 292878) BOWMAN AND BROOKE LLP 970 West 190th Street, Suite 700 Torrance, CA 90502 Telephone: (310) 768-3068 Facsimile: (310) 719-1019 Carissa.casolari@bowmanandbrooke.com Attorneys for Defendants Glock, Inc. and Glock Ges.m.b.H. 19 20 21 22 23 24 25 26 27 28 29 30 31 CASE NO.: 3:20-cv-08807-WHO JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS CERTIFICATION BRIEFING SCHEDULE 1 2 3 4 5 6 7 8 9 [PROPOSED] ORDER The Court, having fully considered the Parties’ Joint Stipulation and [Proposed] Order to Continue Class Certification Briefing Schedule HEREBY ORDERS as follows: 1. The new deadline for Defendants to file an Opposition to Plaintiff’s Motion for Class Certification is February 23, 2024. 2. The new deadline for Plaintiff to file his Reply in support of his Motion for Class Certification is May 23, 2024. 3. The new hearing date on Plaintiff’s Motion for Class Certification is June 12, 2024, at 2:00 p.m. PST. 10 11 IT IS SO ORDERED. 12 13 14 Dated: November 27, 2023 UNITED STATES DISTRICT JUDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 CASE NO.: 3:20-cv-08807-WHO JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND CLASS CERTIFICATION BRIEFING SCHEDULE
]]>
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You
should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google
Privacy Policy and
Terms of Service apply.
