Adamov v. PricewaterhouseCoopers LLP

Filing 92

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 5/7/2018 ORDERING the deadline for class certification discovery is EXTENDED until 90 days after the Court's decision on the later-decided of PwC's Motion for Summary Judgme nt and PwC's Motion for Reconsideration. The deadline for class-related expert witness designation is EXTENDED until 14 days after the class certification discovery cutoff. The deadline to file a motion for class certification is EXTENDED to 28 days after the deadline for class-related expert witness designation. (Zignago, K.)

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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, New York 10166
Telephone: [phone]
Facsimile: [phone]

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Counsel for PricewaterhouseCoopers LLP

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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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[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,
Plaintiff

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Case No. 2:13-cv-01222-TLN-AC
STIPULATION AND ORDER TO
EXTEND CLASS DISCOVERY AND
CLASS CERTIFICATION DEADLINES

v.

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PRICEWATERHOUSECOOPERS LLP, a
Limited Liability Partnership; and DOES 1100, inclusive,
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 (“Local Rule”) 143, Defendant

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PricewaterhouseCoopers LLP (“PwC”) and Plaintiff Yury Adamov (“Plaintiff”), by their

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undersigned counsel, hereby stipulate and jointly request the Court to extend the class discovery

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and class certification deadlines in light of the following circumstances:

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WHEREAS, on July 31, 2017, PwC filed a Motion for Summary Judgment against
Plaintiff, which is fully briefed and pending before the Court (Dkt. Nos. 58, 60 and 61);

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WHEREAS, Magistrate Judge Claire issued an Order on December 22, 2017, granting

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Plaintiff’s discovery motion as to RFP Nos. 1, 3-9, 17, 32 and 37 and denying the motion as to

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RFP Nos. 27, 36, 50-51, 55, 57, 58, 62 and 74 (Dkt. No. 80);

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WHEREAS, on January 19, 2018, PwC filed its Request for Reconsideration of

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Magistrate Judge Claire’s Discovery Order as to RFP Nos. 3-9 and 17 (Dkt. Nos. 87 and 88),

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which is fully briefed and pending before the Court;

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WHEREAS, the Court’s rulings on the pending motions will impact the scope of the

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parties’ further class discovery efforts, the contours of Plaintiff’s motion for class certification, as

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well as Plaintiff’s underlying claims and PwC’s defenses;

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WHEREAS, Mr. Kershaw (lead counsel for Plaintiff and the putative class in this case)

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and other members of his firm will be commencing a five-week jury trial in another matter in San

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Francisco County Superior Court on June 11, 2018;

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WHEREAS, the parties have met and conferred and agree that based on the pending

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motions as well as Mr. Kershaw’s upcoming trial, significant economies will be achieved and

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resources will be conserved for the Court and the parties by extending the class discovery, class-

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related expert designation, and class certification motion deadlines until after the Court decides

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PwC’s Motion for Summary Judgment;

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WHEREAS, the parties previously sought permission from the Court to extend discovery

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and class certification deadlines (Dkt. Nos. 63, 73 and 89) as well as for the deadline on PwC’s

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Request for Reconsideration (Dkt. No. 81). The previously requested extensions were granted

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(Dkt. Nos. 65, 74, 82 and 90); and

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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 and agree that there is good cause for the Court
to enter an Order as follows:

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1. The deadline for class certification discovery is extended until 90 days after the

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Court’s decision on the later-decided of PwC’s Motion for Summary Judgment and

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PwC’s Motion for Reconsideration;

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2. The deadline for class-related expert witness designation is extended until 14 days
after the class certification discovery cutoff; and
3. The deadline to file a motion for class certification is extended to 28 days after the
deadline for class-related expert witness designation.
Dated: May 3, 2018

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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]

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Counsel for Plaintiff

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/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]
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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ORDER

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IT IS SO ORDERED.

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Dated: May 7, 2018

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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