City and County of San Francisco et al v. United States Postal Service et al

Filing 158

STIPULATION AND ORDER REGARDING DEADLINE FOR MOTIONS TO COMPEL FACT DISCOVERY re doc 152 Stipulation, filed by Housing Rights Committee of San Francisco, San Francisco Tenants Union, Central City SRO Collaborative, City and County of San Francisco. Signed by Judge Elizabeth D. Laporte on 6/3/2011. (cgk, COURT STAFF) (Filed on 6/3/2011)

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DENNIS J. HERRERA, City Attorney (State Bar No. 139669)
DANNY CHOU, Chief of Complex and Special Litigation (State Bar No. 180240)
SHERRI SOKELAND KAISER (State Bar No. 197986)
TARA M. STEELEY (State Bar No. 231775)
Deputy City Attorneys
CITY ATTORNEY’S OFFICE
City Hall, Room 234
1 Dr. Carlton B. Goodlett Place
San Francisco, California 94102-4682
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]; [e-mail]
Attorneys for Plaintiff CITY AND COUNTY OF SAN FRANCISCO

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MELINDA HAAG
United States Attorney
JOANN M. SWANSON
Assistant United States Attorney
Chief, Civil Division
JONATHAN U. LEE (CSBN 148792)
THOMAS R. GREEN (CSBN 203480)
Assistant United States Attorneys
Northern District of California
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant UNITED STATES OF AMERICA

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Additional Counsel Listed on Signature Page

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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CITY AND COUNTY OF SAN
FRANCISCO, CENTRAL CITY SRO
COLLABORATIVE, SAN FRANCISCO
TENANTS UNION, and HOUSING RIGHTS
COMMITTEE OF SAN FRANCISCO

Case No. C09-1964 RS
STIPULATION AND PROPOSED ORDER
REGARDING DEADLINE FOR MOTIONS
TO COMPEL FACT DISCOVERY

Plaintiffs,
vs.
UNITED STATES POSTAL SERVICE,
Defendant.

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STIPULATION AND PROPOSED ORDER, CASE NO. CV 09-1964 RS

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BY AND THROUGH THEIR COUNSEL OF RECORD, THE PARTIES STIPULATE AS

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FOLLOWS:

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1. The last day for either plaintiffs or defendant to file a motion to compel further fact

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discovery, as provided in this stipulation, is extended by agreement from June 2, 2011

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to June 9, 2011. This extension will enable the parties to further meet and confer on

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numerous outstanding issue and reduce and perhaps eliminate the issues which may

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require a motion to compel.

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2. The discovery requests subject to the agreement of the parties described in this
stipulation are the following:
a. Plaintiff San Francisco Tenants Union’s Interrogatories to Defendant USPS,
Set #1;
b. Plaintiff City and County of San Francisco’s Requests for Admission to
Defendant USPS, Set #2;
c. Defendant’s Requests for Admission to Plaintiff San Francisco Tenants Union,
Set #2;
d. Defendant’s Requests for Admission to Plaintiff Central City SRO
Collaborative, Set #2;
e. Defendant’s Requests for Admission to Plaintiff Housing Rights Committee of
San Francisco, Set #2;
f. Defendant’s Requests for Admission to Plaintiff City and County of San
Francisco, Set #1;
g. Defendant USPS’ Interrogatories to Plaintiff City and County of San
Francisco, Set #3;
h. Defendant USPS’ Requests for Production to Plaintiff City and County of San
Francisco, Set #4;
i. Defendant USPS’ Requests for Production to Plaintiff Central City SRO
Collaborative, Set #2;
j. Defendant USPS’ Requests for Production to Plaintiff Housing Rights
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Committee of San Francisco, Set #2;

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k. Defendant USPS’ Requests for Production to Plaintiff San Francisco Tenants

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Union, Set #2;

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l. Plaintiffs’ request for additional deposition testimony by Postal Service

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employee Raj Sanghera; and

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m. Topic No. 2 of Defendant’s 30(b)(6) deposition notice served on CCSF and

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related written discovery requests, including Requests for Production Nos. 5,

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12, 36, 41, 45 and 48 and Interrogatory Nos. 26, 29 and 31 served on CCSF.

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3. The parties previously agreed to extend the time for their responses to the discovery

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requests identified in paragraphs (2)(a) through (2)(k) from May 26, 2011 to June 1,

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2011. Counsel for defendant requested the short extension due to a personal family

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emergency for one of the defense team members, and counsel for Plaintiffs agreed as

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a professional courtesy provided that the deadline would be reciprocal.

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4. The parties make this agreement to facilitate any meet and confer efforts that may be

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necessary following service of the responses on June 1, 2011.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED:

June 2, 2011

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MELINDA HAAG
United States Attorney
By:

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/s/ Jonathan U. Lee
JONATHAN U. LEE
Assistant U.S. Attorney
COUNSEL FOR THE UNITED STATES OF
AMERICA

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Dated:

June 2, 2011

COVINGTON & BURLING LLP
By: __/s/ Kelly P. Finley_________________
MICHAEL M. MARKMAN
KELLY P. FINLEY
JOSHUA D. HURWIT
Attorneys for Plaintiffs
CITY AND COUNTY OF SAN FRANCISCO,
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STIPULATION AND PROPOSED ORDER, CASE NO. CV 09-1964 RS

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CENTRAL CITY SRO COLLABORATIVE, SAN
FRANCISCO TENANTS UNION, and HOUSING
RIGHTS COMMITTEE OF SAN FRANCISCO
COUNTY

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Dated:

June 2, 2011

DENNIS J. HERRARA, CITY ATTORNEY

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By:
/s/ Sherri S. Kaiser_______________
SHERRI SOKELAND KAISER
TARA M. STEELEY

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Attorneys for Plaintiff
CITY AND COUNTY OF SAN FRANCISCO

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TENDERLOIN HOUSING CLINIC

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DATED:

June 2, 2011

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By:
/s/ Stephen L. Collier
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STEPHEN L. COLLIER
Attorneys for Plaintiffs
CENTRAL CITY SRO COLLABORATIVE, SAN
FRANCISCO TENANTS UNION, and HOUSING
RIGHTS COMMITTEE OF SAN FRANCISCO
COUNTY

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[PROPOSED] ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED:

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June __, 2011
HON. ELIZABETH D. LAPORTE
United States Magistrate Judge

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