Adamov v. PricewaterhouseCoopers LLP

Filing 65

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 10/3/2017 EXTENDING Discovery and Class Certification Deadlines. Phase I class certification discovery due by 12/7/2017. Plaintiff's Motion for Class Certification shall be filed by 3/9/2018. (Donati, J)

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KERSHAW, COOK & TALLEY PC
William A. Kershaw, State Bar No. 057486
Lyle W. Cook, State Bar No. 148914
Stuart C. Talley, State Bar No. 180374
401 Watt Avenue
Sacramento, California 95864
Telephone: [phone]
Facsimile: [phone]

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Counsel for Plaintiff

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GIBSON, DUNN & CRUTCHER LLP
Daniel J. Thomasch (Admitted Pro Hac Vice)
[e-mail]
Lauren J. Elliot (Admitted Pro Hac Vice)
[e-mail]
200 Park Avenue
New York, NY 10166
Telephone: [phone]
Facsimile: [phone]

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Counsel for PricewaterhouseCoopers LLP
[Additional Counsel Listed on Signature Page]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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YURY ADAMOV, individually, and on behalf
of himself and all other similarly situated
current and former employees of
PricewaterhouseCoopers LLP,

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Case No. 2:13-cv-01222-TLN-AC

STIPULATION AND ORDER TO
EXTEND DISCOVERY AND CLASS
CERTIFICATION DEADLINES

Plaintiffs
v.

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PRICEWATERHOUSECOOPERS LLP, a
Limited Liability Partnership; and DOES 1100, inclusive,

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Defendant.
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STIPULATION AND
ORDER TO EXTEND DEADLINES
CASE NO. 2:13-CV-01222-TLN-AC

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Pursuant to Eastern District of California Civil Local Rule 143, Plaintiff Yury Adamov

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and Defendant PricewaterhouseCoopers LLP, by their undersigned counsel, hereby stipulate as

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follows:

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WHEREAS, on February 6, 2017, the Court issued a Pretrial Scheduling Order (Dkt. No.
51), setting the following deadlines:

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

Class certification discovery cut off: September 14, 2017

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

Designation of class-related expert witnesses and filing of Federal Rule of

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Civil Procedure 26(a)(2)(B) written report(s): November 9, 2017


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Deadline for filing class certification motion: December 14, 2017

WHEREAS, on July 31, 2017, Defendant filed a Motion for Summary Judgment against
Plaintiff Yury Adamov;
WHEREAS, Defendant’s summary judgment motion is fully briefed and awaiting
disposition by the Court;
WHEREAS, the parties have not yet completed class certification discovery, in part due to
the pending potentially dispositive motion;
WHEREAS, the parties have not previously sought permission from the Court to extend
the deadlines related to the February 6, 2017 Pretrial Scheduling Order;
WHEREAS, the parties desire and agree that good cause exists to extend the scheduled

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deadlines to allow additional time for class certification discovery and motion practice and

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Plaintiff’s class certification motion;

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NOW THEREFORE, the parties stipulate that the Court may enter an Order as follows:

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1.

Phase I class certification discovery shall be completed by December 7, 2017.

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2.

All counsel are to designate in writing, file with the Court, and serve upon all other

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parties the name, address, and area of expertise of each expert that they propose to tender at class

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certification not later than February 2, 2018. The designation shall be accompanied by a written

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report prepared and signed by the witness, which shall comply with the Federal Rules of Civil

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Procedure 26(a)(2)(B). Within twenty (20) days after the designation of expert witnesses, any

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STIPULATION AND
ORDER TO EXTEND DEADLINES
CASE NO. 2:13-CV-01222-TLN-AC

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party may designate a supplemental list of expert witnesses who will express an opinion on a

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subject covered by an expert designated by an adverse party.

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3.

Plaintiff’s Motion for Class Certification shall be filed by March 9, 2018.

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4.

The Court’s February 6, 2017 Pretrial Scheduling Order shall otherwise remain in

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effect.

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Dated: September 29, 2017

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Respectfully Submitted,

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/s/ William A. Kershaw ____
KERSHAW, COOK & TALLEY PC
William A. Kershaw
Lyle W. Cook
Stuart C. Talley
401 Watt Avenue
Sacramento, California 95864
Telephone: [phone]
Facsimile: [phone]

/s/ Julie A. Totten _______
GIBSON, DUNN & CRUTCHER LLP
Daniel J. Thomasch
Lauren J. Elliot
200 Park Avenue
New York, NY 10166
Telephone: [phone]
Facsimile: [phone]

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ORRICK HERRINGTON
& SUTCLIFFE LLP
Norman C. Hile
Julie A. Totten
400 Capitol Mall, Suite 3000
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]

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Counsel for Defendant

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Counsel for Plaintiff
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ORDER

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IT IS SO ORDERED.

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Dated: October 3, 2017
Troy L. Nunley
United States District Judge

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STIPULATION AND
ORDER TO EXTEND DEADLINES
CASE NO. 2:13-CV-01222-TLN-AC