STIPULATION AND [PROPOSED] ORDER CASE NO.: 09-1511 MMC 

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Eric A. Grover, Esq. (SBN 136080) 

Jade Butman, Esq. (SBN 235920) 

KELLER GROVER LLP 

425 Second Street, Suite 500 

San Francisco, California 94107 

Tel. (415) 543-1305; Fax: (415) 543-7861 

eagrover@kellergrover.com 

jbutman@kellergrover.com

Scot Bernstein, Esq. (SBN 94915) 

LAW OFFICES OF SCOT D. BERNSTEIN, 

A PROFESSIONAL CORPORATION 

101 Parkshore Drive, Suite 100 

Folsom, California 95630 

Tel. (916) 447-0100 

Fax (916) 933-5533 

Attorneys for Plaintiff 

Marcello Gabrielli 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

MARCELLO GABRIELLI, on behalf of 

himself, the general public, and as an 

“aggrieved employee” under the California 

Labor Code Private Attorneys General Act, 

 Plaintiff, 

 v. 

 

CHIPOTLE MEXICAN GRILL, INC., 

CHIPOTLE MEXICAN GRILL SERVICE 

CO., LLC., and DOES 1 through 10 

inclusive, 

 Defendants. 

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Case No.: 09-1511 MMC 

CLASS ACTION

STIPULATION AND [PROPOSED] 

ORDER TO EXTEND CERTAIN 

CASE DEADLINES SET BY CASE 

MANAGEMENT ORDER 

[Complaint filed March 4, 2009] 

Trial Date: None Set 

Case 3:09-cv-01511-MMC Document 21 Filed 01/28/10 Page 1 of 3
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STIPULATION AND [PROPOSED] ORDER CASE NO.: 09-1511 MMC 

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 The parties, through their respective counsel, hereby stipulate as follows, and 

mutually request the Court to approve this Stipulation and enter its Order accordingly: 

STIPULATION

 WHEREAS Plaintiff filed the Complaint herein on March 4, 2009 and 

and Defendants appeared and answered when they removed the case to this Court; 

 WHEREAS an initial case management conference was held on July 24, 

2009; 

 WHEREAS at the initial case management conference the Court set a 

deadline of February 15, 2010 for the cut off of class certification discovery and a 

deadline of March 29, 2010 for the filing of a motion for class certification; 

 WHEREAS the parties have exchanged initial disclosures and engaged in 

formal discovery such as requesting and producing documents, propounding 

interrogatories, and appearing for Plaintiff’s deposition; 

 WHEREAS although Defendants have worked diligently to provide 

discovery responses, meet and confer over the discovery response, and provide 

supplemental responses, such efforts have taken longer than anticipated by the parties; 

 WHEREAS the parties have been working cooperatively to keep the 

process of discovery moving along; 

 WHEREAS despite the parties best efforts to comply with the deadlines 

set by the initial case management order, the parties need additional time to adequately 

complete class certification discovery and need to extend the deadline for Plaintiff to file 

his motion for class certification; 

 WHEREAS the parties have mutually agreed to extend the deadline for 

completing class certification discovery and the deadline for filing Plaintiff’s motion for 

class certification; 

 THEREFORE, the parties stipulate that the deadline for completing class 

certification discovery currently scheduled for February 15, 2010 should be continued 

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STIPULATION AND [PROPOSED] ORDER CASE NO.: 09-1511 MMC 

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until May 16, 2010; and the deadline to file Plaintiff’s motion for class certification 

currently set for March 29, 2010 should be continued until June 27, 2010. 

Dated: January 27, 2010 KELLER GROVER LLP

 By: /s/ 

ERIC A. GROVER 

Attorneys for Plaintiff 

Marcello Gabrielli 

Dated: January 27, 2010 SHEPPARD MULLIN RICHTER & HAMPTON LLP

 By: /s/ 

GEOFFREY DEBOSKY 

 Attorneys for Defendants 

Chipotle Mexican Grill, Inc., and 

Chipotle Mexican Grill Service Co. 

ORDER

 Good cause appearing, IT IS HEREBY ORDERED THAT the deadline 

for completing class certification discovery currently scheduled for February 15, 2010 is 

continued until May 16, 2010 and the deadline to file Plaintiff’s motion for class 

certification currently set for March 29, 2010 is continued until June 27, 2010. 

Date: _________________________ 

 _________________________________ 

 MAXINE M. CHESNEY 

 United States District Court Judge 

Case 3:09-cv-01511-MMC Document 21 Filed 01/28/10 Page 3 of 3