STIPULATION RELATING TO CLASS CERTIFICATION MOTION; ORDER THEREON 

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WOODALL LAW OFFICES 

100 PINE STREET, SUITE 1250 

SAN FRANCISCO, CALIFORNIA 94111 

TELEPHONE: (415) 413-4629 

FACSIMILE: (866) 937-4109 

KEVIN@KWOODALLLAW.COM 

KEVIN F. WOODALL, BAR NO. 180650 

BARNES LAW OFFICES 

580 CALIFORNIA ST., 16TH FLOOR 

SAN FRANCISCO, CA 94104 

TELEPHONE: (415) 231-6110 

FACSIMILE: (888) 415-0801 

PAGE@PBARNESLAW.COM 

PAGE R. BARNES, BAR NO. 153539 

ATTORNEYS FOR PLAINTIFF, STARVONA HARRIS, 

JONATHAN STRICKLAND AND THOSE SIMILARLY SITUATED

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

OAKLAND DIVISION 

STARVONA HARRIS AND JONATHAN

STRICKLAND, INDIVIDUALLY AND ON 

BEHALF OF THOSE SIMILARLY SITUATED, 

 PLAINTIFFS, 

V. 

BEST BUY STORES, L.P., A LIMITED 

PARTNERSHIP, 

 DEFENDANT. 

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CASE NO. 4:17-CV-00446 HSG

STIPULATION RELATING TO CLASS 

CERTIFICATION MOTION; ORDER 

THEREON 

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 STIPULATION RELATING TO CLASS CERTIFICATION; ORDER THEREON 

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In June, 2017, the parties submitted a Joint Case Management Conference 

Statement, in which both parties requested that Plaintiffs file their class certification 

motion in October, 2017. [Dkt. No. 42.] In response, the Court set a deadline for a 

hearing relating to the class certification motion of November 30, 2017, along with a 

normal briefing schedule. [Dkt. No. 44.] Thus, the contemplated filing date was October 

26, 2017 (35 days prior to November 30, 2017). The Court also set other deadlines, 

including a discovery deadline of September 29, 2017. Plaintiffs’ counsel noticed that as 

of late last week, the Court’s scheduling notes indicate that no hearing dates are available 

prior to November 30, 2017. Consequently, Plaintiffs are concerned the November 30, 

2017 hearing date will be taken well before it is prepared to file a class certification 

motion by late October, 2017. 

Magistrate Judge Westmore also ordered Defendant to produce documents and 

information that Plaintiffs intend to use for class certification, which is due on September 

22, 2017. [Dkt. No. 72.] The parties also have a number of discovery issues that, if not 

resolved very soon, will need to be addressed by Magistrate Judge Westmore. 

Given the above and the parties’ desire for additional time to file opposition and 

reply briefs relating to the class certification motion, the parties enter into this stipulation. 

IT IS HEREBY STIPULATED as follows: 

1. Plaintiffs shall have until October 26, 2017 to file their motion for class 

certification; 

2. Defendant shall have three weeks after Plaintiffs’ class certification motion is 

filed to file their opposition to Plaintiffs’ motion for class certification; 

3. Plaintiffs shall have two weeks after Defendant’s opposition to class 

certification is filed to file their reply brief in support of class certification; 

4. The hearing date shall be the first available date on the Court’s calendar, which 

takes into consideration the briefing schedule above and is at least two weeks 

after Plaintiffs’ reply brief is filed. 
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