Case 5:22-cv-00372-BLF Document 37 Filed 05/31/22 Page 1 of 3
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`LAW OFFICE OF J. CONOR CORCORAN, P.C.
`J, CONOR CORCORAN, ESQUIRE
`(PA Atty. Id. No. 8911 Admitted Pro Hac Vice)
`conor@jccesq.com
`1650 Market Street, Suite 3600
`Philadelphia, PA 19103
`Tel: (215) 735-1135
`Fax: (215) 735-1175
`Counsel for Plaintiff
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`JARED WEINSTOCK, ESQUIRE (SB# 252335)
`jaredweinstock@gmail.com
`4295 Bakman Avenue
`North Hollywood, CA 91602
`Phone: (310) 702-1224
`Fax: (215) 735-1175
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`Attorneys for Plaintiff
`SWEET CICELY DANIHER
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SWEET CICELY DANIHER,
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`CASE NO. 5:22-cv-00372-BLF
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`Plaintiff,
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`vs.
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`PIXAR ANIMATION STUDIOS; PIXAR
`TALKING PICTURES; WALT DISNEY
`MOTION PICTURES GROUP; and KORI
`RAE
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`Defendants.
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`JOINT STIPULATION TO STAY
`AND ORDER
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`JOINT STIPULATION TO STAY (22-CV-
`00372)
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`Case 5:22-cv-00372-BLF Document 37 Filed 05/31/22 Page 2 of 3
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`WHEREAS, the Court held a Case Management Conference on May 12, 2022;
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`WHEREAS, on May 17, 2022, the Court issued a Case Management Order (Dkt. No. 35),
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`ordering, among other things, that:
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`1.
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`“The deadline for joinder of any additional parties, or other amendments to the
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`pleadings, is sixty days after entry of this order;”
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`2.
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`“The deadline for the parties to meet, confer, and submit a stipulation and order
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`setting all deadlines not set by the Court below, including discovery cut-offs and
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`expert disclosure deadlines, May 27, 2022;” and
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`3.
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`“Unless previously ordered or stipulated, the parties shall meet and confer further in
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`order to reach an agreement on an ADR process within 10 days of the date of this
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`Order. Within that same time frame, the parties shall either (1) file the form entitled
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`‘Stipulation and (Proposed) order Selecting ADR Process’ if an agreement is
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`reached, or (2) file the form entitled ‘Notice of Need of ADR Phone Conference’.”
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`WHEREAS, the parties have discussed and are continuing to discuss (i) a potential
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`resolution to this case and (ii) a schedule for amended pleadings and motion practice if no resolution
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`is reached;
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`WHEREAS, in the interest of efficiency and judicial economy, the parties have agreed to
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`stay this case for thirty (30) days while pursuing the aforementioned resolution;
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`WHEREAS, by prior stipulations subsequently granted by the Court, the Parties (i)
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`extended Defendants’ deadline to answer or otherwise respond to Plaintiff’s Complaint by thirty
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`(30) days (Dkt. No. 17) and then, given Plaintiff’s Motion to Remand, to the date that is thirty (30)
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`days after the Court issues an order deciding that Motion (Dkt. No. 19), now set as June 9, 2022,
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`and (ii) set a briefing schedule for Plaintiff’s Motion to Remand (Dkt. No. 23);
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`- 1 -
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`JOINT STIPULATION TO STAY (22-CV-
`00372)
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`Case 5:22-cv-00372-BLF Document 37 Filed 05/31/22 Page 3 of 3
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`WHEREAS, other than (i) Defendants’ June 9, 2022 deadline to answer or otherwise
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`respond to Plaintiff’s Complaint and (ii) the deadlines set forth above from the Case Management
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`Order, this stipulated stay will not affect the case schedule or alter the date of any event or deadline
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`already fixed by Court order.
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`NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, pursuant to Local
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`Civil Rule 6-2, by and between Plaintiff and Defendants, through their undersigned counsel, that
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`the above-captioned lawsuit shall be stayed for thirty (30) days, through and including June 27,
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`2022. All deadlines pending in the above-captioned lawsuit as of May 27, 2022 shall be extended
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`for thirty (30) days.
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`DATED: May 27, 2022
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`PAUL HASTINGS LLP
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`LAW OFFICE OF J. CONOR CORCORAN,
`P.C.
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`By: /s/ Josh B. Gordon
`Josh B. Gordon
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`By: /s/ J. Conor Corcoran
`J. Conor Corcoran
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`Attorneys for Defendants Pixar Animation
`Studios, Pixar Talking Pictures, Walt Disney
`Motion Pictures Group, and Kori Rae
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`Attorneys for Plaintiff Sweet Cicely
`Daniher
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`PURSUANT TO STIPULATION, IT IS SO ORDERED.
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`May 31, 2022
`Date: ________________________
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`By: ___________________________
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`Hon. Beth Labson Freeman
`U.S. District Judge
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`Filer’s Attestation
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`I, J. Conor Corcoran, am the ECF user whose identification and password are being used to
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`file this JOINT STIPULATION TO STAY. In compliance with Civil Local Rule 5-1(h)(3), I
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`hereby attest that the above-named signatories concur in this filing.
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`- 2 -
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`JOINT STIPULATION TO STAY (22-CV-
`00372)
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