Adamov v. PricewaterhouseCoopers LLP

Filing 74

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 11/27/2017 ORDERING that Phase I class certification discovery shall be COMPLETED by 1/19/2018. All other dates currently set forth in this Courts 10/4/2017 Pre-Trial Scheduling Order as set forth above, shall remain in full force and effect. (Hunt, G)

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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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Plaintiffs

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

STIPULATION AND ORDER TO
EXTEND DISCOVERY AND CLASS
CERTIFICATION DEADLINES

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 and

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jointly request the Court to extend ONLY the class certification related discovery cutoff date

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from December 7, 2017 to January 19, 2018 while keeping all other currently scheduled

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(previously ordered) dates the same, in light of the following events;

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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 Civil

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

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

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WHEREAS, on July 31, 2017, Defendant filed a Motion for Summary Judgment against

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Deadline for filing class certification motion: December 14, 2017.

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, on October 4, 2017 the parties requested and the Court agreed to amend the
Pretrial Scheduling Order (Dkt. No. 65) setting the following deadlines:

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

Phase I class certification discovery cut off: December 7, 2017.

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

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

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Procedure 26(a)(2)(B) written report(s): February 2, 2018.
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Within twenty (20) days after the designation of expert witnesses, any party may

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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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

Deadline for filing class certification motion: March 9, 2018.

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

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

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

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WHEREAS, following extensive meet and confer efforts during the summer and fall of

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2017, Plaintiff scheduled a Motion to Compel Production of Documents, which was initially set

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for hearing on November 8, 2017. However, given the magnitude of the Joint Statement to be

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provided the Court, Plaintiff agreed to extend the hearing date one week to November 15, 2017.

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After some communication with the Court, the parties submitted a Stipulation and Proposed

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Order to that effect. However, on November 1, 2017 the Court entered an Order setting the

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Motion to Compel Production of Documents Hearing for November 22, 2017;

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WHEREAS, it became clear during the week of November 20, 2017 that travel to and

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from the east coast would be exceedingly difficult on the day before the Thanksgiving Holiday,

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and PwC requested that the Motion to Compel Hearing be put over until November 29, 2017.

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Given these travel issues, Plaintiff agreed to accommodate this request. However, due to a

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conflicting hearing date on November 29, 2017, Plaintiff’s counsel suggested the matter be set on

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December 6, 2017. The parties agreed and submitted a Stipulation and Proposed Order to that

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effect (Dkt. No. 71);

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WHEREAS, in light of the discovery cutoff date for certification related discovery having

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previously been set for December 7, 2017 by the Honorable Troy Nunley, the Court has declined

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to hear Plaintiff’s Motion To Compel Production of Documents on December 6, 2017 unless

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Judge Nunley, having previously issued the case scheduling order, agrees to amend that order

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extending the discovery cutoff date for certification related discovery (Dkt. No. 72);

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WHEREAS, the parties therefore request that the Court, while maintaining all previously

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set scheduling deadlines, extend the class certification related discovery cutoff date from

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December 7, 2017 to January 19, 2018 to allow the parties to conclude law and motion related

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matters.

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

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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 January 19, 2018. All other
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dates currently set forth in this Courts October 4, 2017 Pre-Trial Scheduling Order as
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set forth above, shall remain in full force and effect.
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Dated: November 21, 2017

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Respectfully Submitted,
/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/ Daniel J. Thomasch
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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: November 27, 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