Saperstein v. Greenberg Traurig, LLP

Filing 7

STIPULATION AND ORDER signed by District Judge John A. Mendez on 3/21/2016 ORDERING the parties to confer as required by F.R.Cv.P. 26(f), and prepare and submit to the Court a joint status report that includes the Rule 26(f) discovery plan, by 5/2/2016. (Michel, G.)

1
2
3
4
5
6
7
8
9
10

MICHAEL P. McNAMARA (SBN 106079)
KIRSTEN H. SPIRA (SBN 119885)
STEPTOE & JOHNSON LLP
2121 Avenue of the Stars, Suite 2800
Los Angeles, California 90067-5052
Telephone: [phone] // Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
MORGAN L. HECTOR (SBN 246573)
STEPTOE & JOHNSON LLP
633 West Fifth Street, Suite 700
Los Angeles CA 90071
Telephone: [phone] // Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant
GREENBERG TRAURIG, LLP

11
12
13

UNITED STATES DISTRICT COURT

14

EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

15

GARRY SAPERSTEIN,

16
Plaintiff,

17
18
19
20
21

Case No.: 2:16-cv-00271-JAM-EFB
Hon. John A. Mendez

v.

JOINT STIPULATION AND ORDER TO
GREENBERG TRAURIG, LLP, and DOES 1 CONTINUE JOINT STATUS REPORT,
RULE 26(f) DISCOVERY PLAN, AND
through 100, inclusive,
RELATED DEADLINES
Defendants.

22
23
24
25
26
27
28

STIPULATION AND PROPOSED ORDER
Doc. # DC-9011964 v.1

1
2

JOINT STIPULATION
TO THE HONORABLE COURT: This Stipulation to continue, by three weeks, the

3
4

deadline to file a joint status report, Rule 26(f) discovery plan, and to confer as required by Fed.

5

R. Civ. P. 26(f) is made by and between Plaintiff Gary Saperstein and Defendant Greenberg

6

Traurig, LLP (“Defendant”), with respect to the following facts:

7
8
9
10

1.

On February 11, 2016, Defendant removed this case from El Dorado Superior

Court to this Court.
2.

On February 11, 2016, the Court entered an Order Requiring Joint Status Report

11

requiring that, “[w]ithin sixty (60) days of … the date of removal, the parties shall confer as

12

required by Fed. R. Civ. P. 26(f) and shall prepare and submit to the Court a joint status report

13

that includes the Rule 26(f) discovery plan.” Dkt. No., ¶4.

14
15
16
17
18
19

3.

Sixty days from the date of the removal is April 11, 2016.

4.

Defendant is currently in the process of transferring this file from counsel of

record, Steptoe & Johnson LLP (“Steptoe”), to new counsel, Jenner & Block LLP (“Jenner”).
5.

Counsel of record Michael McNamara and Kirsten Spira are similarly in the

process of transitioning from Steptoe to Jenner, and expect that process to be completed by mid-

20
21
22

April 2016.
6.

Counsel for Plaintiff and Defendant met and conferred on March 16, 2016 and

23

agreed that for the convenience of the parties and their counsel of record and to maximize the

24

efficiency of this case in light of the transition to new counsel, the deadlines set forth in the

25
26
27

Court’s Order Requiring Joint Status Report should be continued three weeks to allow for the
transition to new counsel to be completed.

28
1
STIPULATION AND PROPOSED ORDER
Doc. # DC-9011964 v.1

1

THEREFORE, ALL PARTIES HEREBY STIPULATE AND RESPECTFULLY

2

REQUEST THAT THE COURT continue the parties’ deadlines to confer as required by Fed.

3

R. Civ. P. 26(f), and prepare and submit to the Court a joint status report that includes the Rule

4

26(f) discovery plan, by three weeks, from April 11, 2016 to May 2, 2016.

5
6
7

IT IS SO STIPULATED.
STEPTOE & JOHNSON LLP

Dated: March 18, 2016

8
9

By:

/s/ Kirsten Spira
KIRSTEN SPIRA
Attorneys for Defendant
GREENBERG TRAURIG, LLP

10
11
12
13

RING HUNTER HOLLAND & SCHENONE
LLP

Dated: March 18, 2016

14

By:

/s/ Justin Schnitzler [as Authorized
on March 18, 2016]
JUSTIN SCHNITZLER
Attorneys for Plaintiff
GARRY SAPERSTEIN

15
16
17
18
19
20
21
22
23
24
25
26
27
28
2

STIPULATION AND PROPOSED ORDER
Doc. # DC-9011964 v.1

1
2
3
4
5

IT IS SO ORDERED.
Dated: 3/21/2016
/s/ John A. Mendez_________________
HON. JOHN A. MENDEZ
UNITED STATES DISTRICT JUDGE

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
STIPULATION AND PROPOSED ORDER
Doc. # DC-9011964 v.1