On November 05, 2014 a
Stipulation,Agreement
was filed
involving a dispute between
All Other Persons Similarly Situated,
Xxxxxxxx Xxxx,
and
Hornblower Cruises & Events,
Hornblower New York, Llc,
Hornblower Yachts, Inc.,
Terry Macrae,
for Contract (Non-Commercial)
in the District Court of New York County.
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YO Ip TH ap
NYSGEF DOC. NO. 27 RECEIVED NYSCEF: 12/11/2015
\|
SUPREME COURT OF THE STATE OF NEW YORK
_ COUNTY OF NEW YORK
xxxxxxxx xxxx and STAR JADA RIVERA, on Index No.: 160993/2014
behalf of themselves and others similarly situated,
STIPULATION TO EXTEND
Plaintiffs, PRE-CLASS CERTIFICATION
DISCOVERY AND THE
-against- DEADLINE FOR CLASS
CERTIFICATION
HORNBLOWER NEW YORK, LLC;
HORNBLOWER YACHTS, INC.; HORNBLOWER
CRUISES & EVENTS; TERRY MACRAE, and any
other related entities,
Defendants.
WHEREAS, the parties are still engaged in pre-class certification discovery and working
to resolve outstanding discovery issues;
IT IS NOW THEREFORE STIPULATED AND AGREED BY AND BETWEEN
THE ATTORNEYS FOR THE PARTIES IN THIS ACTION THAT:
Qa) The deadline to complete pre-certification discovery, currently due to be
completed by December 8, 2015, shall be extended to January 8, 2016;
@) Defendants will produce. the following outstanding discovery, as
addressed during the parties’ November 11, 2015 meet and confer session, by December
7, 2015:(1) event files from the October 31, 2014 event that began at 9:00 p.m.; and (2)
all correspondence to and from customers and complete event files not already produced
by Defendants relating to the specific events allegedly worked by the Pint
|. —~¥
@) Plaintiffs to conduct the deposition of Defendants’ witness, Cameron
Clark', by December 22, 2015 at Virginia & Ambinder’s offices at 40 Broad St, 7" Floor,
New York, NY;
- .
@ Plaintiffs’ motion for class certification shall be filed by January 15, 2016;
Defendants’ opposition papers shall be filed by February 15, 2016; and Plaintiffs’ reply
papers shall be filed by March 7, 2016.
This stipulation may be executed in counterparts and any photocopy, fax or other
electronic transmission of the same is deemed to be an original.
Dated: November 30, 2015
‘New York, New York
Sz . P=?
AA Rsgioi\
Suzanne Leeds Klein, Esq, ith
VIRGINIA & AMBINDER, LLP KANEK SSLER, P.C.
40 Broad Street, 7th Floor 1350 Avenue of the Americas
‘New York, New York 10004 ‘New York, New York 10019
.
Attorneys for Defendants
Jeffrey K, Brown, Esq
Michael Tompkins, Esq,
LEEDS BROWN LAW, P.C.
One Old Country Road, Suite 347
Carle Place, New York 11514
Attorneys for Plaintiffs
BOK HK
AD
HON. CAROL ff: EDME
' Defendants have desi ignated Mr. Cameron Clark as the corporate representative with knowledge of the claims
defenses in this matter. end
Document Filed Date
December 11, 2015
Case Filing Date
November 05, 2014
Category
Contract (Non-Commercial)
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YO Ip TH ap NYSGEF DOC. NO. 27 RECEIVED NYSCEF: 12/11/2015 \| SUPREME COURT OF THE STATE OF NEW YORK _ COUNTY OF NEW YORK xxxxxxxx xxxx and STAR JADA RIVERA, on Index No.: 160993/2014 behalf of themselves and others similarly situated, STIPULATION TO EXTEND Plaintiffs, PRE-CLASS CERTIFICATION DISCOVERY AND THE -against- DEADLINE FOR CLASS CERTIFICATION HORNBLOWER NEW YORK, LLC; HORNBLOWER YACHTS, INC.; HORNBLOWER CRUISES & EVENTS; TERRY MACRAE, and any other related entities, Defendants. WHEREAS, the parties are still engaged in pre-class certification discovery and working to resolve outstanding discovery issues; IT IS NOW THEREFORE STIPULATED AND AGREED BY AND BETWEEN THE ATTORNEYS FOR THE PARTIES IN THIS ACTION THAT: Qa) The deadline to complete pre-certification discovery, currently due to be completed by December 8, 2015, shall be extended to January 8, 2016; @) Defendants will produce. the following outstanding discovery, as addressed during the parties’ November 11, 2015 meet and confer session, by December 7, 2015:(1) event files from the October 31, 2014 event that began at 9:00 p.m.; and (2) all correspondence to and from customers and complete event files not already produced by Defendants relating to the specific events allegedly worked by the Pint |. —~¥ @) Plaintiffs to conduct the deposition of Defendants’ witness, Cameron Clark', by December 22, 2015 at Virginia & Ambinder’s offices at 40 Broad St, 7" Floor, New York, NY; - . @ Plaintiffs’ motion for class certification shall be filed by January 15, 2016; Defendants’ opposition papers shall be filed by February 15, 2016; and Plaintiffs’ reply papers shall be filed by March 7, 2016. This stipulation may be executed in counterparts and any photocopy, fax or other electronic transmission of the same is deemed to be an original. Dated: November 30, 2015 ‘New York, New York Sz . P=? AA Rsgioi\ Suzanne Leeds Klein, Esq, ith VIRGINIA & AMBINDER, LLP KANEK SSLER, P.C. 40 Broad Street, 7th Floor 1350 Avenue of the Americas ‘New York, New York 10004 ‘New York, New York 10019 . Attorneys for Defendants Jeffrey K, Brown, Esq Michael Tompkins, Esq, LEEDS BROWN LAW, P.C. One Old Country Road, Suite 347 Carle Place, New York 11514 Attorneys for Plaintiffs BOK HK AD HON. CAROL ff: EDME ' Defendants have desi ignated Mr. Cameron Clark as the corporate representative with knowledge of the claims defenses in this matter. end