Coleman, et al v. Schwarzenegger, et al

Filing 7344

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 10/13/2021 EXTENDING the deadlines in 7191 Order as follows: Fact Discovery shall be completed by 12/16/2021, Expert Disclosure due by 1/14/2022, Rebuttal Expert Disclosur e due by 1/28/2022, All Expert Discovery shall be completed by 2/11/2022, Dispositive and Daubert motions shall be filed by 3/4/2022 and shall be noticed for hearing and briefing in accordance with the provisions of Local Rule 230. If necessary, an evidentiary hearing will be set for a date in June or July 2022. (Huang, H)

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SHAWNA BALLARD, State Bar No. 155188
KATE FALKENSTIEN, State Bar No. 313753
Reichman Jorgensen Lehman & Feldberg LLP
100 Marine Parkway, Suite 300
Redwood Shores, CA 94065
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]

BRIAN C. BARAN, State Bar No. 325939
Reichman Jorgensen Lehman & Feldberg LLP
1710 Rhode Island Ave NW, 12th Floor
Washington, DC 20036
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

Attorneys for Plaintiff-Intervenor
Christopher Lipsey
ROB BONTA, State Bar No. 202668
Attorney General of California
MONICA N. ANDERSON, State Bar No. 182970
Senior Assistant Attorney General
DAMON MCCLAIN, State Bar No. 209508
Supervising Deputy Attorney General
ELISE OWENS THORN, State Bar No. 145931
NAMRATA KOTWANI, State Bar No. 308741
Deputy Attorneys General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants

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HANSON BRIDGETT LLP
PAUL B. MELLO, State Bar No. 179755
SAMANTHA D. WOLFF, State Bar No. 240280
LAUREL E. O’CONNOR, State Bar No. 305478
DAVID C. CASARRUBIAS, State Bar No. 321994
1676 N. California Boulevard, Suite 620
Walnut Creek, CA 94596
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
ROMAN M. SILBERFELD, State Bar No. 62783
GLENN A. DANAS, State Bar No. 270317
ROBINS KAPLAN LLP
2049 Century Park East, Suite 3400
Los Angeles, CA 90067-3208
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Special Counsel for Defendants

IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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RALPH COLEMAN, et al.
Plaintiffs,

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Case No. 2:90-cv-00520 KJM DB P

v.
GAVIN NEWSOM, et al.,
Defendants.

STIPULATION AND ORDER EXTENDING
DEADLINES FOR ADJUDICATING
PLAINTIFF-INTERVENOR CHRISTOPHER
LIPSEY’S CLAIM
Judge:
Hon. Kimberly Mueller
Action Filed: April 23, 1990

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On June 3, 2021, the Court issued an order adopting the parties’ proposed schedule to

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adjudicate Plaintiff-Intervenor Christopher Lipsey’s claim in intervention. See ECF No. 7191. Under

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that schedule, fact discovery was to be completed by October 29, 2021. Id. ¶ 2. Other deadlines for
expert discovery and dispositive and Daubert motions followed from the fact discovery cutoff. Id. ¶
3.

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Lipsey and Defendants have been actively engaged in discovery but need more time to

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complete it. The magistrate judge granted in part Lipsey’s motion to compel on September 10, 2021,

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requiring time for the parties to negotiate the additional document productions contemplated by that

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order and time for Defendants to review and produce documents accordingly. Additionally, while

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Defendants had initially completed their production of documents not at issue in the motion to compel
on August 25, 2021, they recently discovered an error in the execution of search terms that
significantly expands the volume of documents to be reviewed and produced. Given these outstanding

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tasks to complete document production, it is not feasible for Defendants to finish producing

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documents, Lipsey to review the newly produced documents, and the parties to complete depositions

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by October 29. The parties therefore request an extension of discovery deadlines.

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IT IS STIPULATED AS FOLLOWS:
The parties jointly stipulate and request that the deadlines set forth in the June 3, 2021 order
be extended as follows:
1. Fact discovery shall be completed by December 16, 2021.

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2. The parties shall disclose experts by January 14, 2022.

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3. The parties shall disclose rebuttal experts by January 28, 2022.

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4. All expert discovery shall be completed by February 11, 2022.

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5. Dispositive and Daubert motions shall be filed by March 4, 2022 and shall be noticed for
hearing and briefing in accordance with the provisions of Local Rule 230.
Case No. 2:90-cv-00520 KJM DB P

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Stipulation and Order Extending Deadlines
for Lipsey’s Claim

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6. If necessary, an evidentiary hearing will be set for a date in June or July 2022.

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Dated: September 28, 2021
/s/ Kate Falkenstien
REICHMAN JORGENSEN
LEHMAN & FELDBERG LLP
Shawna L. Ballard (SBN 155188)
Kate Falkenstien (SBN 313753)
100 Marine Parkway, Suite 300
Redwood Shores, California 94065
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

Respectfully submitted,
/s/ Elise Owens Thorn (as authorized on 9/28/21)
ROB BONTA
Attorney General of California
DAMON MCCLAIN
Supervising Deputy Attorney General
ELISE OWENS THORN
Deputy Attorney General
Attorneys for Defendants

REICHMAN JORGENSEN
LEHMAN & FELDBERG LLP
Brian C. Baran (SBN 325939)
1710 Rhode Island Ave NW, 12th Floor
Washington, DC 20036
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff-Intervenor
Christopher Lipsey

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IT IS SO ORDERED.
Dated: October 13, 2021.

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Case No. 2:90-cv-00520 KJM DB P

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Stipulation and Order Extending Deadlines
for Lipsey’s Claim