Retiree Support Group of Contra Costa County v. Contra Costa County

Filing 94

STIPULATION AND ORDER re 93 STIPULATION WITH PROPOSED ORDER Regarding Discovery Limits and Case Deadlines filed by Retiree Support Group of Contra Costa County. Fact Discovery due by 1/20/2015. Expert Disclosures due by 2/23/2015. Expert Rebuttal due by 3/12/2015. Expert Discovery due by 4/9/2015. Dispositve Motions due by 5/7/2015. Pretrial Conference Statement due by 6/22/2015. Final Pretrial Conference set for 6/30/2015 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Bench Trial set for 7/20/2015 - 7/24/2015 at 8:30 AM before Hon. Jon S. Tigar. Signed by Judge Jon S. Tigar on June 4, 2014. (wsn, COURT STAFF) (Filed on 6/4/2014)

1 LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C.
ANDREW LAH, SBN 234580
2 [e-mail]
NINA WASOW, SBN 242047
3 [e-mail]
DARIN RANAHAN, SBN 273532
4 [e-mail]
476 9th Street
5 Oakland, CA 94607
Telephone:
[phone]
6 Facsimile:
[phone]
7 Attorneys for Plaintiff
RETIREE SUPPORT GROUP OF CONTRA COSTA COUNTY
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HANSON BRIDGETT LLP
9 RAYMOND F. LYNCH, SBN 119065
[e-mail]
10 STEPHEN B. PECK, SBN 72214
[e-mail]
11 JANE M. FEDDES, SBN 282117
[e-mail]
12 425 Market Street, 26th Floor
San Francisco, California 94105
13 Telephone:
[phone]
Facsimile:
[phone]
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Attorneys for Defendant
15 CONTRA COSTA COUNTY
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RETIREE SUPPORT GROUP OF CONTRA
20 COSTA COUNTY,

CASE NO. C 12-00944 JST

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STIPULATION REGARDING
DISCOVERY LIMITS AND CASE
DEADLINES AND [PROPOSED] ORDER

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Plaintiff,
v.

23 CONTRA COSTA COUNTY,
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Judge: Hon. Jon S. Tigar

Defendant.

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WHEREAS, the parties have diligently engaged in discovery and have substantially

27 completed document discovery;
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6039202.2

WHEREAS, the parties have only taken one deposition (out of a total of, most likely, 30C 12-00944 JST
STIPULATION RE DISCOVERY LIMITS AND CASE DEADLINES AND [PROPOSED] ORDER

1 40) and anticipate propounding additional Interrogatories;
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WHEREAS, Plaintiff and Defendant anticipate filing motions to compel production of

3 documents that have been withheld on the basis of privilege after they have exhausted meet and
4 confer efforts;
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WHEREAS, the parties wish to continue to meet and confer on these and other discovery

6 matters and resolve as many discovery issues as possible without Court intervention;
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WHEREAS, the parties have reached a compromise regarding the disputed issues set forth

8 in their most recent Joint Case Management Statement (Dkt. 91), and no longer need the Court’s
9 assistance in resolving these disputes;
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NOW THEREFOR, the parties, by and through their respective counsel of record, hereby

11 stipulate and agree to the following:
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(1) Plaintiff and Defendant may each propound up to 40 interrogatories without first
obtaining leave of the Court.
(2) Plaintiff and Defendant may each take up to 20 depositions without first obtaining
leave of the Court.
(3) Plaintiff agrees not to pursue its objection to Defendant’s temporal limitation on

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document production, provided Plaintiff is also not required to produce documents

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created after July 1, 2011, and provided Defendant agrees to produce the most recent

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set of Memoranda of Understanding and Salary Resolutions.

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(4) All case deadlines will be extended as follows:

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Event

Deadline

Fact discovery cut-off

1/20/15

Expert disclosures

2/23/15

Expert rebuttal

3/12/15

Expert discovery cut-off

4/9/15

Deadline to file dispositive motions

5/7/15

Pretrial conference statement due

6/22/15

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6039202.2

C 12-00944 JST
-2STIPULATION RE DISCOVERY LIMITS AND CASE DEADLINES AND [PROPOSED] ORDER

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Pretrial conference

6/30/15 at 2:00 p.m. or such other date
available on the Court’s schedule

Bench trial

7/20/15 at 8:30 a.m. or such other date
available on the Court's trial schedule

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IT IS SO STIPULATED.

6 DATED: June 2, 2014

LEWIS, FEINBERG, LEE, RENAKER &
JACKSON, P.C.

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By:

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12 DATED: June 2, 2014

/s/Nina Wasow
NINA WASOW
Attorneys for Plaintiff
RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY
HANSON BRIDGETT LLP

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DERED
SO OR
IT IS
HONORABLE JON S. TIGAR

United States District Court Judge

nS
J u d ge J o

ER

H

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RT

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June 4 2014
____,

NO

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Dated:

. Ti ga r

A

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IT IS SO ORDERED.

UNIT
ED

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C

TA

RT
U
O

S

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R NIA

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/s/Raymond Lynch
RAYMOND F. LYNCH
Attorneys for Defendant
S DISTRICT
CONTRA COSTA COUNTY
TE

FO

By:

LI

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N

F
D IS T IC T O
R

C

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C 12-00944 JST
-3STIPULATION RE DISCOVERY LIMITS AND CASE DEADLINES AND [PROPOSED] ORDER

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SIGNATURES UNDER GENERAL ORDER NO. 45

2 Pursuant to General Order No. 45 of the United States District Court, Northern District of
3 California, I, Nina Wasow—the ECF User whose User ID and Password are used in the filing of
4 this document—hereby attest that the concurrence to the filing of this document has been obtained
5 from each of the other signatories to this document.
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/s/Nina Wasow
Nina Wasow

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6039202.2

C 12-00944 JST
-4STIPULATION RE DISCOVERY LIMITS AND CASE DEADLINES AND [PROPOSED] ORDER