Liu v. Astrue

Filing 24

STIPULATION AND ORDER REGARDING DISCOVERY AND MOTION TO COMPEL DISCOVERY re 23 STIPULATION WITH PROPOSED ORDER RE DISCOVERY filed by Lan T. Liu. Signed by Magistrate Judge Jacqueline Scott Corley on October 25, 2012. (wsn, COURT STAFF) (Filed on 10/25/2012)

Case3:11-cv-06120-JSC Document23 Filed10/24/12 Page1 of 4

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MARY DRYOVAGE (SBN 112551)
Law Offices of Mary Dryovage

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351 California Street, Suite 700
San Francisco, CA 94104
Telephone: [phone]
Email: [e-mail]
WENDY MUSELL (SBN 203507)
Stewart & Musell

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351 California Street, Suite 700
San Francisco, CA 94104
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff
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MELINDA L. HAAG (SBN: 132612)
United States Attorney
ALEX G. TSE (152348)
Chief, Civil Division
JUAN D. WALKER (SBN 208008)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
FAX: [phone]
Email: [e-mail]
Attorney for Federal Defendant

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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Case No. C-11-6120 (JSC)

LAN T. LIU,
Plaintiff,
v.
MICHAEL J. ASTRUE, SECRETARY
SOCIAL SECURITY ADMINISTRATION,

STIPULATION AND [PROPOSED]
ORDER REGARDING DISCOVERY AND
MOTION TO COMPEL DISCOVERY

Defendant.

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND MOTION TO COMPEL
DISCOVERY
Liu v. Astrue, Case No. C-11-6120 (JSC)
Page 1

Case3:11-cv-06120-JSC Document23 Filed10/24/12 Page2 of 4

WHEREAS, the close of discovery in the above titled matter was October 15, 2012, and

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motions to compel discovery are currently due by October 25, 2012;

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WHEREAS the legal counsel for the parties have met in person for meet and confer

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regarding outstanding discovery issues in an effort to resolve and/or limit the remaining

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discovery disputes between the parties, LAN T. LIU, Plaintiff and MICHAEL J. ASTRUE,

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COMMISSIONER OFSOCIAL SECURITY, Defendant (hereinafter “Parties”), request the

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following relief by the Court.

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(1)

Defendant agrees to amend the following responses to Plaintiff’s Request for

Production of Documents, Set One: 6, and 9;

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(2)

Defendant agrees to amend/reevaluate the following responses to Plaintiff’s

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Request for Production of Documents, Set One: 7, and 12;
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(3)

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Defendant agrees to reevaluate the following responses to Plaintiff’s Request for

Production of Documents, Set Two to determine if a supplement will be provided: 1;
(4)

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Defendant agrees to amend the following responses to Plaintiff’s Interrogatory

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Requests, Set One: 1, (requests nos. 3, 4, 5, 6 incorporate by reference request No. 1), 7, 8, and

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13;

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(5)

Defendant agrees to amend the following responses to Plaintiff’s Request for

Admissions, Set One: 6, and 10;

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(6)

Defendant agrees to reevaluate the following responses to Plaintiff’s Request for

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Admissions, Set One to determine if a supplement will be provided: 12 and 20;
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(7)

Defendant agrees to provide a privilege log;

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(8)

Defendant agrees to provide verifications for each of its interrogatory responses;

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(9)

Plaintiff agrees to supplement Defendant’s Request for Interrogatories Nos. 9 and

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10;

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND MOTION TO COMPEL
DISCOVERY
Liu v. Astrue, Case No. C-11-6120 (JSC)
Page 2

Case3:11-cv-06120-JSC Document23 Filed10/24/12 Page3 of 4

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(10)

Plaintiff agrees to reevaluate the following responses to Defendant’s Interrogatory

Requests, Set One to determine if a supplement will be provided: 2, 3, 4, and 8;
(11)

Agreement could not be reached regarding Plaintiff’s Interrogatory Requests Nos.

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10-25 and Plaintiff’s Request for Production of Documents, Set One Request Nos. 4, 8, and 10,

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and the parties anticipate they will be the subject of a motion to compel/ request for additional

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discovery as it relates to these requests;

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(12)

Both parties will provide supplemental responses by November 7, 2012;

(13)

The parties will meet and confer regarding these supplemental responses by

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November 14, 2012; and
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(14)

Any motion to compel regarding the above requests is due to the Court by

November 28, 2012. Any discovery dispute shall be brought in accordance with this
Court's Standing Order on or before November 28, 2012.

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Dated: October 24, 2012

/s/ electronic signature authorized
MARY DRYOVAGE
Law Offices of Mary Dryovage

Dated: October 24, 2012

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_/s/ electronic signature authorized
WENDY MUSELL
Stewart & Musell, LLP

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Attorneys for Plaintiff

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Dated: October 24, 2012
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MELINDA L. HAAG
United States Attorney
/s/ electronic signature
_________________
JUAN D. WALKER
Assistant United States Attorney
Attorneys for Federal Defendant

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND MOTION TO COMPEL
DISCOVERY
Liu v. Astrue, Case No. C-11-6120 (JSC)
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Case3:11-cv-06120-JSC Document23 Filed10/24/12 Page4 of 4

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IT IS SO ORDERED.

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October 25, 2012
Dated:_________________
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_________________________________
JACQUELINE SCOTT CORLEY
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY AND MOTION TO COMPEL
DISCOVERY
Liu v. Astrue, Case No. C-11-6120 (JSC)
Page 4