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)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 JAMES R. MCGUIRE (CA SBN 189275) JMcGuire@mofo.com GREGORY P. DRESSER (CA SBN 136532) GDresser@mofo.com RITA F. LIN (CA SBN 236220) RLin@mofo.com AARON D JONES (CA SBN 248246) AJones@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: 415.268.7000 Facsimile: 415.268.7522 JON W. DAVIDSON (CA SBN 89301) JDavidson@lambdalegal.org SUSAN L. SOMMER (pro hac vice) Ssommer@lambdalegal.org TARA L. BORELLI (CA SBN 216961) TBorelli@lambdalegal.org LAMBDA LEGAL DEFENSE AND EDUCATION FUND, INC. 3325 Wilshire Boulevard, Suite 1300 Los Angeles, California 90010-1729 Telephone: 213.382.7600 Facsimile: 213.351.6050 Attorneys for Plaintiff KAREN GOLINSKI 15 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 SAN FRANCISCO DIVISION 19 20 KAREN GOLINSKI, Plaintiff, 21 22 23 24 Case No. v. UNITED STATES OFFICE OF PERSONNEL MANAGEMENT, and JOHN BERRY, Director of the United States Office of Personnel Management, in his official capacity, 25 Defendant. 26 27 28 [PROPOSED] SCHEDULING ORDER CASE NO. 3:10-CV-0257-JSW sf-3021755 3:10-cv-0257-JSW [PROPOSED] ORDER SCHEDULING DISCOVERY AND BRIEFING ON PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 1 It is hereby ORDERED that the following schedule is established to govern discovery in 2 3 this matter and briefing on Plaintiff Karen Golinski’s (“plaintiff”) motion for summary judgment: 4 1. Defendant-Intervenor, The Bipartisan Legal Advisory Group of the U.S. House of 5 Representatives (“the House”) and plaintiff (collectively, “the parties”), shall exchange all written 6 requests for discovery (including document requests, interrogatories and requests for admission 7 pursuant to Fed. R. Civ. P. 26, 33, 34, and 36) on or before August 12, 2011; 2. The House shall identify its experts (if any) on or before August 15, 2011 (plaintiff has 8 9 already identified her experts); 3. The House shall serve its expert reports (if any) on or before August 22, 2011 (plaintiff 10 11 has already served her expert reports); 4. Plaintiff may take depositions of the House’s experts (if any) beginning on August 23, 12 13 2011; 14 5. All fact and expert discovery shall be completed by September 15, 2011; 15 6. Plaintiff shall file a renewed motion for summary judgment on or before September 30, 16 17 18 19 20 21 2011; 6. The House shall file its opposition to plaintiff’s motion for summary judgment on or before October 14, 2011; 7. Plaintiff may submit a reply in support of her motion for summary judgment on or before October 28, 2011; 8. The parties hereby stipulate that the depositions of the expert witnesses in Windsor v. 22 United States, No. 10-cv-8435 (S.D.N.Y.) and Pedersen v. Office of Personnel Management, No. 23 310-cv-1750 (D. Conn.), who are the same five experts designated by the plaintiff, are admissible 24 in this case. Plaintiff’s experts shall not be re-deposed in this case without leave of Court. 25 26 9. A hearing on plaintiff’s motion for summary judgment is set for November ____, 2011, at ______ a.m. 27 28 [PROPOSED] SCHEDULING ORDER CASE NO. 3:10-CV-0257-JSW sf-3021755 1 1 2 IT IS SO ORDERED. 3 Dated: _____________, 2011. 4 The Honorable Jeffrey S. White United States District Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [PROPOSED] SCHEDULING ORDER CASE NO. 3:10-CV-0257-JSW sf-3021755 2

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