Nadeau et al v. Wealth Counsel LLC et al
Filing
25
ORDER signed by District Judge Morrison C. England, Jr on 11/28/2017 ORDERING that: The stay should be lifted as of 11/15/2017; Plaintiffs will file their Opposition to Defendants Motion to Transfer (ECF No. 21) by 12/1/2017; Defendants will file the ir Answer to Plaintiffs First Amended Complaint within 15 days after service of the First Amended Complaint; The Parties will be deemed to have conferred with respect to discovery on 11/15/2017; The Parties will exchange their initial disclosures pursuant to Rule 26(a) on 12/11/2017. (Hunt, G)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Alan J. Reinach, State Bar No. 196899
Email: ajreinach@churchstate.org
CHURCH STATE COUNCIL
2686 Townsgate Road
Westlake Village, CA 91361
Telephone (805) 413-7398
Joseph E. Maloney, State Bar No. 95458
Email: joseph.maloney@jmaloneylaw.com
12005 Peregrine Way
Auburn, CA 95603
Telephone (530) 885-7787
Attorneys for Plaintiffs
LAURIE NADEAU, ROBYN COFFIN and DAGNY
MAGELSSEN
Mark J. Jacobs, State Bar No. 208945
Email: mjacobs@fisherphillips.com
Christopher S. Alvarez, State Bar No. 294795
Email: calvarez@fisherphillips.com
FISHER & PHILLIPS LLP
621 Capitol Mall, Suite 1400
Sacramento, CA 95814
Telephone (916) 210-0400
Facsimile (916) 210-0401
Attorneys for Defendants
WEALTH COUNSEL, LLC and INSPERITY, INC.
16
IN THE UNITED STATES DISTRICT COURT
17
FOR THE EASTERN DISTRICT OF CALIFORNIA
18
19
20
LAURIE NADEAU; ROBYN
COFFIN; and DAGNY MAGELSSEN,
21
22
Case No. 2:17-cv-00561-MCE-AC
Plaintiffs,
JOINT STATEMENT OF THE
CASE
v.
23
24
25
WEALTH COUNSEL, LLC;
INSPERITY, INC.,
Complaint Filed: March 15, 2017
Trial Date: None Set
Defendants.
26
27
28
1
JOINT STATEMENT OF THE CASE
FPDOCS 33444316.1
1
Plaintiffs Laurie Nadeau; Robyn Coffin; and Dagny Magelssen
2
(“Plaintiffs”) and Defendants WealthCounsel, LLC and Insperity, Inc.
3
(“Defendants,” together with Plaintiffs referred to as the “Parties”) hereby submit
4
this Joint Statement of the Case.
5
1.
The parties were unable to resolve the matter at the mediation.
6
2.
The stay should be lifted as of November 15, 2017.
7
3.
As provided in the Order filed September 13, 2017 (ECF No. 20),
8
the case shall be deemed opened for purposes of this Court’s Initial Scheduling
9
Order (ECF No. 3) as of November 15, 2017.
10
11
12
13
14
15
16
17
4.
(ECF No. 21) by December 1, 2017.
5.
Plaintiffs will file their First Amended Complaint to include federal
claims under Title VII.
6.
Defendants will file their Answer to Plaintiffs’ First Amended
Complaint within fifteen (15) days after service of the First Amended Complaint.
7.
The Parties have conferred regarding discovery matters pursuant to
Federal Rule of Civil Procedure 26(f) and agreed as follows:
a.
18
19
Plaintiffs will file their Opposition to Defendants Motion to Transfer
discovery on November 15, 2017;
b.
20
The Parties will exchange their initial disclosures
pursuant to Rule 26(a) on December 11, 2017;
ii.
23
24
The discovery plan is as follows:
i.
21
22
The Parties will be deemed to have conferred with respect to
Discovery will be needed on all the issues of liability
and damages and should not be limited or phased;
iii.
25
Electronically stored documents will be produced in
26
PDF format, if practical, and other documents will be produced in a convenient
27
format;
28
2
JOINT STATEMENT OF THE CASE
FPDOCS 33444316.1
iv.
1
The Parties do not anticipate issues about claims of privilege
2
or protection of trial preparation materials, and any such issues that arise will be
3
addressed on an ad hoc basis;
v.
4
Because there are three Plaintiffs and two Defendants,
5
the limitations on discovery will be doubled, except that depositions will be
6
limited to 10 hours on the record spread over two days unless extended pursuant
7
to the Parties agreement or Court order;
vi.
8
Depositions will not be noticed until after January 8,
9
2018, so that the parties will, in the interim, concentrate on written discovery.
10
Any deposition of Karl Clegg or Brett Pinegar will take place in Salt Lake City.
11
Any depositions of the plaintiffs will take place in Sacramento. Any deposition of
12
Tamira Ryan will take place in Sacramento, and Defendants will produce her so
13
long as she is employed. Any depositions of the owners will take place in the
14
cities in which they practice.
15
7.
Aside from documents filed through the Court’s electronic service,
16
the Parties agree to electronic service of documents, including, among other
17
things, documents produced during discovery. For purposes of calculating
18
respective deadlines, documents initially served electronically will be treated as if
19
they were served by mail adding three additional days, and responses thereto
20
electronically served will be treated as if they were served by personal service.
21
Electronic service will include service to the following individuals and addresses:
22
Alan Reinach: MisterLiberty@churchstate.org;
23
Jonathon Cherne: attorneycherne@gmail.com
24
Joseph Maloney: Joseph.maloney@jmaloneylaw.com, and
25
26
27
Joseph.maloney@sbcglobal.net;
Mark Jacobs: mjacobs@fisherphillips.com, and
ecamanag@fisherphillips.com; and
28
3
JOINT STATEMENT OF THE CASE
FPDOCS 33444316.1
1
2
Christopher Alvarez: calvarez@fisherphillips.com; and
amalerbi@fisherphillips.com.
3
4
DATE: November 15, 2017
CHURCH STATE COUNCIL
5
6
By: /s/ Joseph E. Maloney_______
Joseph E. Maloney
7
Attorneys for Plaintiffs
LAURIE NADEAU, ROBYN COFFIN
and DAGNY MAGELSSEN
8
9
10
11
DATE: November 15, 2017
FISHER & PHILLIPS LLP
12
13
By: _/s/ Christopher S. Alvarez_____
Mark J. Jacobs
Christopher S. Alvarez
14
15
Attorneys for Defendants
WEALTH COUNSEL, LLC and
INSPERITY, INC.
16
17
18
ORDER
19
20
IT IS SO ORDERED.
21
22
Dated: November 28, 2017
23
24
25
26
27
28
4
JOINT STATEMENT OF THE CASE
FPDOCS 33444316.1
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?