Barnes et al v. The Hershey Company
Filing
122
ORDER re 121 Status Report. The parties' joint discovery letter brief is due 3/14/2014. Signed by Judge Nathanael M. Cousins on 3/5/2014. (nclc2, COURT STAFF) (Filed on 3/5/2014)
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Morgan, Lewis & Bockius LLP
1701 Market Street
Philadelphia, PA 19103-2921
Tel. 215.963.5000
Fax: 215.963.5001
www.morganlewis.com
Michael J. Puma
Partner
215.963.5305
mpuma@morganlewis.com
March 5, 2014
VIA ECF FILING
The Honorable Nathaniel Cousins
Magistrate Judge of the United States
District Court, Northern District of California
Courtroom A, 15th Floor
450 Golden Gate Avenue
San Francisco, CA 94103
Re:
Barnes, et al. v. The Hershey Company
Case No.: 3:12-cv-01334-CRB
Dear Judge Cousins:
RT
Almaty Beijing Boston Brussels Chicago Dallas Dubai* Frankfurt Harrisburg Houston Irvine
Moscow New York Palo Alto Paris Philadelphia Pittsburgh Princeton San Francisco Tokyo
*In association with Mohammed Buhashem Advocates & Legal Consultants
A
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. Cousins
FO
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thanael M
Judge Na
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IT IS S
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Very truly yours,
/s/ Michael J. Puma
Michael J. Puma
Attorney for Defendant
/s/ Thomas J. Brandi
THOMAS J. BRANDI
Attorney for Plaintiffs
S
The parties submit this joint status report as required by Your Honor’s February 7, 2014
Opinion and Order (ECF 118). On February 7, 2014, the parties agreed to a Stipulation
Regarding Protocol for Document Production Including Electronically Stored Information and
Data, the Obligation for Document Preservation, and the Procedure for the Protection and
Assertion of Privilege. Since that time the parties have been negotiating search terms and the
protocol for reviewing and producing documents returned by those search terms. During those
negotiations, disputes have arisen. The parties have been unable to resolve these disputes and
anticipate seeking the Court’s intervention. To that end, the parties anticipate filing a joint
discovery dispute letter by March 14, 2014.
N
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D IS T IC
London Los Angeles Miami T O
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Washington Wilmington
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