Golinski v. United States Office of Personnel Management

Filing 155

Declaration of Rita F. Lin in Support of 154 Reply to Opposition/Response, Of Bipartisan Legal Advisory Group's Opposition To Her Motiobn For Summary Judgment filed byKaren Golinski. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Related document(s) 154 ) (Lin, Rita) (Filed on 7/22/2011)

From:

Lin, Rita F.

Sent:

Tuesday, July 19, 2011 12:29 AM

To:

'Christopher Bartolomucci'; [e-mail]

Cc:

[e-mail]

Subject:

Golinski: proposed summary judgment schedule

Attachments: Golinski proposed order re MSJ scheduling - 1.DOC
Chris and Chris,
We wanted to touch base with you about the proposed summary judgment schedule attached to BLAG's
summary judgment opposition brief. We don't think any further discovery has been shown to be
necessary. To allow things to move forward quickly if the Court disagrees, however, we wanted to meet
and confer with you regarding the schedule BLAG proposed.
If the Court believes additional discovery to be necessary, we would be amenable to the schedule
proposed, with the revisions reflected in the attached proposed order. As you can imagine, we will want
to re-file our motion for summary judgment to account for what happens in discovery. To accommodate
that, we have suggested some modification of the expert deadlines and the close of discovery. We also
added a stipulation regarding the depositions of the experts. Please let me know if you are agreeable to
our revisions. We would like to be able to represent your position to the Court in our filing on Friday.
Best,
Rita
Rita Lin | Morrison & Foerster LLP
425 Market Street | San Francisco, California 94105
Tel. [phone] | Fax [phone]