Chandler v. City of Emeryville et al

Filing 28

STIPULATION AND ORDER re 26 Stipulation filed by Edward Suen, City of Emeryville. Signed by Judge Edward M. Chen on 7/17/09. (bpf, COURT STAFF) (Filed on 7/17/2009)

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Kathleen Maylin (State Bar No. 155371) JACKSON LEWIS LLP 199 Fremont Street, 10th Floor San Francisco, California 94105 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Defendants CITY OF EMERYVILLE and EDMUND SUEN Pamela Y. Price (State Bar No. 107713) Eun Grace Chung (State Bar No. 259766) PRICE AND ASSOCIATES A Professional Law Corporation 1611 Telegraph Avenue, Suite 1450 Oakland, California 94612 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] E-mail: [e-mail] Attorneys for Plaintiff CRAIG CHANDLER UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

CRAIG CHANDLER, Plaintiff, v. CITY OF EMERYVILLE, EDMUND SUEN IN HIS INDIVIDUAL CAPACITY, AND DOES 1 THROUGH 15, INCLUSIVE, Defendants.

Case No. C08-4010 EMC JOINT STIPULATION REGARDING PRODUCTION OF DEPOSITION TRANSCRIPT AND [PROPOSED] ORDER Complaint Filed: 08/21/08 Amended Complaint Filed:

09/26/08

Plaintiff CRAIG CHANDLER ("Plaintiff") and Defendant CITY OF EMERYVILLE ("Defendant") enter into the following Joint Stipulation Regarding the Production of Deposition Transcript as follows:

WHEREAS, in 2008, former City of Emeryville employee Reza Bonabi had his 1 Case No. C08-4010 EMC STIP. RE PRODUCTION OF DEPO. TRANSCRIPT AND [PROPOSED] ORDER

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deposition taken in workers' compensation proceedings unrelated to this action. At one point during Plaintiff's employment, Mr. Bonabi, as Information Systems Manager with the City, supervised Plaintiff; WHEREAS, Plaintiff believes that he is entitled to review Mr. Bonabi's workers' compensation deposition transcripts in the course of discovery in this action; WHEREAS, Defendants believe that they are unable to produce Mr. Bonabi's deposition testimony without a Court order as its production would be a violation of Mr. Bonabi's personnel privacy rights; WHEREAS, if the transcript is ordered to be produced, Plaintiff agrees to limit further disclosure per the terms of the Stipulated Protective Order; THEREFORE, in light of the foregoing, the parties hereby stipulate as follows: 1. Defendant agrees that, if this Court orders the production of Mr. Bonabi's

workers' compensation transcript, they will produce said transcripts to Plaintiff within five (5) business days pursuant to the Stipulated Protective Order to be executed by the parties. Attached hereto as Exhibit A is a true and correct copy of the proposed Stipulated Protective Order and [Proposed] Order. IT IS SO STIPULATED. Dated: July 14, 2009 By: JACKSON LEWIS LLP /s/ Kathleen Maylin Kathleen Maylin Attorneys for Defendants CITY OF EMERYVILLE and EDMUND SUEN

Dated: July 14, 2009 By:

PRICE AND ASSOCIATES /s/ Pamela Price Pamela Y. Price Eun Grace Chung Attorneys for Plaintiff CRAIG CHANDLER

2 Case No. C08-4010 EMC STIP. RE PRODUCTION OF DEPO. TRANSCRIPT AND [PROPOSED] ORDER

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[PROPOSED] ORDER Having reviewed the Stipulation of the parties, and good cause appearing, the Court orders as follows: 1. Defendant shall produce Mr. Bonabi's workers' compensation transcript pursuant

to the Stipulated Protective Order to be executed by the parties. IT IS SO ORDERED.

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UNIT ED

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Dated:

July 17, 2009

EDWARD M. CHEN United States DistrictEREDMagistrate Judge ORD Court
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