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

Filing 165

ORDER REGARDING DEADLINE FOR DISCOVERY MOTIONS RE: FACT DISCOVERY 159 . Signed by Judge Elizabeth D. Laporte on 6/13/2011. (lmh, COURT STAFF) (Filed on 6/13/2011)

1
2
3
4
5
6
7
8

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

16

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

17

Additional Counsel Listed on Signature Page

9
10
11
12
13
14
15

18

UNITED STATES DISTRICT COURT

19

NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

20
21
22
23
24
25
26
27

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 DISCOVERY
MOTIONS RE: FACT DISCOVERY

Plaintiffs,
vs.
UNITED STATES POSTAL SERVICE,
Defendant.

28
STIPULATION AND PROPOSED ORDER, CASE NO. CV 09-1964 RS

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

BY AND THROUGH THEIR COUNSEL OF RECORD, THE PARTIES STIPULATE AS
FOLLOWS:
1. The parties continue to meet and confer regarding Topic No. 2 of Defendant’s
30(b)(6) deposition notice served on CCSF and the following written discovery
requests to the extent they relate to Topic No. 2: Requests for Production Nos. 5, 12,
36, 41, 45, 48, 89, 93-94, 97-100 and 102, Interrogatory Nos. 26, 29, 31 and 32 and
Requests For Admission Nos. 3-4, 7, 45-51, 77, 92, 123-184 served on CCSF.
Though outstanding issues remain, the parties continue to meet and confer regarding
these issues and are making progress in eliminating issues the Court may otherwise
need to address.
2. Defendant will make Raj Sanghera available for additional deposition testimony
regarding topics about which she was previously instructed not to testify. The parties
continue to meet and confer regarding the schedule for Ms. Sanghera’s additional
deposition. The deadline for Plaintiffs to move to compel additional testimony from
Ms. Sanghera shall be the same deadline as set forth in paragraph 4.
3. The current deadline by which the parties may file a discovery motion relating to these
matters is Thursday June 9, pursuant to the stipulation and proposed order signed by
the Court on June 3.
4. To provide the parties sufficient time to take depositions and attempt to resolve any
outstanding issues covered by these discovery requests, the parties agree to extend the
time to move to compel or preclude any fact discovery relating to these requests until
one week following the last Topic 2 deposition.

23
24

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

25
26
27
28
-3STIPULATION AND PROPOSED ORDER, CASE NO. 09-1964 RS

1
DATED:

June 9, 2011

2

MELINDA HAAG
United States Attorney

3
By:
4
5
6
7

Dated:

June 9, 2011

8

COVINGTON & BURLING LLP
By: __/s/ Kelly P. Finley_________________
MICHAEL M. MARKMAN
KELLY P. FINLEY
JOSHUA D. HURWIT

9
10

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

11
12
13
14

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

Dated:

June 9, 2011

DENNIS J. HERRARA, CITY ATTORNEY

15

17

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

18

Attorneys for Plaintiff
CITY AND COUNTY OF SAN FRANCISCO

16

19
20

PURSUANT TO STIPULATION, IT IS SO ORDERED.

22

S

RT

27

ER

H

28
-4-

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

e

. Laport

D
lizabeth
Judge E

NO

26

R NIA

ERED

HON. ELIZABETH D. ORD
IS SO LAPORTE
I Magistrate Judge
United States T

FO

13
June ___, 2011

LI

25

DATED:

UNIT
ED

24

RT
U
O

23

S DISTRICT
TE
C
TA

A

21

[PROPOSED] ORDER

N

F
D IS T IC T O
R

C