City of Los Angeles, et al. v. Sprint Solutions, Inc. et al.

Filing 113

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/2/21 AMENDING the pretrial scheduling order as follows: Close of Fact Discovery: 11/17/21; Opening expert reports: 12/17/21; Responsive expert reports: 2/1/22; Close of expert discovery: 3/1/22; Dispositive Motion Hearing Deadline: 5/5/22. (Kastilahn, A)

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Colin H. Murray (State Bar No. 159142)
[e-mail]
Anne M. Kelts (State Bar No. 298710)
[e-mail]
BAKER & McKENZIE LLP
Two Embarcadero Center, 11th Floor
San Francisco, CA 94111-3802
Telephone: [phone]
Facsimile: [phone]
John E. Joiner (admitted Pro Hac Vice)
[e-mail]
William P. Ashworth (admitted Pro Hac Vice)
[e-mail]
Anna K. Tsiotsias (State Bar No. 319520)
[e-mail]
WILLIAMS & CONNOLLY LLP
725 Twelfth Street, N.W.
Washington, D.C. 20005
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
SPRINT SOLUTIONS, INC. and
NEXTEL OF CALIFORNIA, INC.
[Additional counsel on signature page]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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CITY OF LOS ANGELES, ex rel. RICHARD
KNUDSEN,

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Plaintiffs,

Case No. 2:17-cv-00811-TLN-AC
STIPULATION AND ORDER
MODIFYING PRETRIAL
SCHEDULING ORDER

vs.
SPRINT SOLUTIONS, INC.; NEXTEL OF
CALIFORNIA, INC., D/B/A NEXTEL
COMMUNICATIONS AND SPRINT
NEXTEL; and DOES 1-10,

Judge:
Hon. Troy L. Nunley
Courtroom: 2, 15th Floor
Trial Date: None set

Defendants.

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Case No. 2:17-cv-00811-TLN-AC
STIPULATION AND ORDER MODIFYING PRETRIAL SCHEDULING ORDER

JOINT STIPULATION AND ORDER SETTING CASE SCHEDULE

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WHEREAS on April 28, 2020 the Court entered a Pretrial Scheduling Order setting the
discovery and dispositive motion deadlines for the above-captioned case;
WHEREAS, document production in this matter involves locating, reviewing and producing
over 13 years of records from the parties as well as substantial third-party discovery;
WHEREAS, the parties have worked diligently to move discovery forward, and have made
substantial progress, but need more time to complete discovery due to the ongoing impact of the
COVID-19 pandemic;
WHEREAS, the parties have also discussed ways to streamline the cost and expense of the
expert reports in this litigation and believe bifurcating damages quantification analysis will assist
them in preparing dispositive motions in a cost effective manner and in pursuing potential resolution
of these claims;
IT IS HEREBY STIPULATED AND AGREED by and between the parties and their
undersigned counsel, subject to the approval of the Court, that the pretrial scheduling order will be
modified as follows:

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Event

Deadline

Close of Fact Discovery

November 17, 2021
December 17, 2021

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Opening expert reports for parties with the
burden of proof (excluding reports related to the
quantification of damages)
Responsive expert reports (excluding reports
related to the quantification of damages)
Close of expert discovery

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Dispositive Motion Hearing Deadline

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February 1, 2022
March 1, 2022
May 5, 2022

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Expert disclosures and discovery related to the
quantification of damages

Following the Court’s Ruling on Motions for
Summary Judgment

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Case No. 2:17-cv-00811-TLN-AC
STIPULATION AND ORDER MODIFYING PRETRIAL SCHEDULING ORDER

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Dated: April 2, 2021

BAKER & McKENZIE LLP
Colin H. Murray
Anne M. Kelts

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WILLIAMS & CONNOLLY LLP
John E. Joiner
William P. Ashworth

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By: /s/ William P. Ashworth
William P. Ashworth

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Attorneys for Defendants
Sprint Solutions, Inc. and
Nextel of California, Inc.

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Dated: April 2, 2021

COTCHETT, PITRE & McCARTHY LLP
Niall P. McCarthy
Eric J. Buescher

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By: /s/ Eric J. Buescher
Eric J. Buescher

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Attorneys for Plaintiff City of Los Angeles

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ORDER

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IT IS SO ORDERED.

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Dated: April 2, 2021

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Troy L. Nunley
United States District Judge

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Case No. 2:17-cv-00811-TLN-AC
STIPULATION AND ORDER MODIFYING PRETRIAL SCHEDULING ORDER