Ingram v. Pacific Gas & Electric Company et al

Filing 152

STIPULATION AND ORDER re 151 STIPULATION WITH PROPOSED ORDER REQUESTING CONTINUANCE OF DEADLINE REGARDING DISCOVERY DISPUTES filed by PG&E Corporation, Pacific Gas & Electric Company. Signed by Judge Jon S. Tigar on May 13, 2014. (wsn, COURT STAFF) (Filed on 5/13/2014)

LAFAYETTE & KUMAGAI LLP
GARY T. LAFAYETTE (State Bar No. 088666)
REBECCA K. KIMURA (State Bar No. 220420)
100 Spear Street, Suite 600
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants
PACIFIC GAS AND ELECTRIC COMPANY and
PG&E CORPORATION

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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600
94105
[phone]
[phone]

Plaintiff,

PACIFIC GAS AND ELECTRIC
COMPANY; PG&E CORPORATION and
DOES 1 through 20, inclusive,
FAX

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vs.
SAN FRANCISCO, CALIFORNIA

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ATTORNEYS AT LAW

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STIPULATION AND REQUEST TO
CONTINUE DEADLINE REGARDING
DISCOVERY DISPUTES; [PROPOSED]
ORDER

SPEAR STREET, SUITE

[phone]
[phone]
FAX

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Case No. CV 12 2777 JST

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LAFAYETTE & KUMAGAI LLP

STEVEN INGRAM,

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600
94105
SAN FRANCISCO, CALIFORNIA

ATTORNEYS AT LAW

SPEAR STREET, SUITE

100

LAFAYETTE & KUMAGAI LLP

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Complaint Filed: May 21, 2012

Defendants.

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STIPULATION AND REQUEST TO CONTINUE DEADLINE REGARDING DISCOVERY DISPUTES;
[PROPOSED] ORDER (Case No. CV 12-2777-JST)

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STIPULATION AND REQUEST
Plaintiff Steven Ingram (“Plaintiff”) and Defendants Pacific Gas and Electric Company

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and PG&E Corporation (“Defendants”) (collectively referred to as the “Parties”) through their

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respective counsel hereby stipulate as follows:

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WHEREAS on April 28, 2014, the Court issued an Amended Order Deferring Summary
Judgment Proceedings (Dkt. No. 150) (the “Order”);

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WHEREAS paragraph 2 of the Order requires the Parties to meet and confer and propose

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a special master for appointment by May 12, 2014;

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WHEREAS paragraph 4 of the Order requires the Parties to file any other extant

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discovery disputes by May 12, 2014, to be addressed by Judge Spero; and

600
94105

[phone]
[phone]

between the Parties through their respective attorneys of record that the deadline to propose a
special master for appointment and the deadline to file any other extant discovery disputes be
extended by three days to May 15, 2014.
FAX

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SAN FRANCISCO, CALIFORNIA

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ATTORNEYS AT LAW

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND REQUESTED by and

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100

[phone]
[phone]
FAX

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discovery disputes but need additional time to meet the deadlines set forth above;
SPEAR STREET, SUITE

LAFAYETTE & KUMAGAI LLP

WHEREAS the Parties are continuing to meet and confer regarding all outstanding

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600
94105
SAN FRANCISCO, CALIFORNIA

ATTORNEYS AT LAW

SPEAR STREET, SUITE

100

LAFAYETTE & KUMAGAI LLP

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DATED: May 12, 2014

SMITH PATTEN

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/s/ Spencer F. Smith
SPENCER F. SMITH
Attorneys for Plaintiff
STEVEN INGRAM

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DATED: May 12, 2014

LAFAYETTE & KUMAGAI LLP
/s/ Rebecca K. Kimura
REBECCA K. KIMURA
Attorneys for Defendants
PACIFIC GAS AND ELECTRIC COMPANY and
PG&E CORPORATION

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STIPULATION AND REQUEST TO CONTINUE DEADLINE REGARDING DISCOVERY DISPUTES;
[PROPOSED] ORDER (Case No. CV 12-2777-JST)

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SIGNATURE ATTESTATION

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I hereby attest that I have obtained the concurrence of Spencer F. Smith, counsel for

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Plaintiff, for the filing of this stipulation.

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/s/ Rebecca K. Kimura
REBECCA K. KIMURA

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Good cause appearing therefor and pursuant to the parties’ stipulation, it is hereby

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ORDERED that the deadline to propose a special master for appointment and the deadline to file

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any other extant discovery disputes be extended by three days to May 15, 2014.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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[phone]
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600
94105
ATTORNEYS AT LAW

SAN FRANCISCO, CALIFORNIA

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SPEAR STREET, SUITE

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100

LAFAYETTE & KUMAGAI LLP

FAX

[phone]
[phone]

600
94105
SAN FRANCISCO, CALIFORNIA

ATTORNEYS AT LAW

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IT I

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SPEAR STREET, SUITE

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JON S. TIGAR
RED
United States SO ORJudge
District DE
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DATED: May 13, 2014

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LAFAYETTE & KUMAGAI LLP

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STIPULATION AND REQUEST TO CONTINUE DEADLINE REGARDING DISCOVERY DISPUTES;
[PROPOSED] ORDER (Case No. CV 12-2777-JST)

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