Hall et al v. Housing Authority of the County of Marin

Filing 45

STIPULATION AND ORDER RE CHANGES TO SCHEDULING ORDER RE MOTIONS AND DISCOVERY, AS MODIFIED BY THE COURT. Signed by Judge Richard Seeborg on 11/8/13. (cl, COURT STAFF) (Filed on 11/8/2013)

Case3:12-cv-04922-RS Document44 Filed11/06/13 Page1 of 4

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Frank Sommers (State Bar No. 109012)
Andrew Schwartz (State Bar No. 100210)
SOMMERS & SCHWARTZ LLP
One Embarcadero Center, Suite 800
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Karen Carrera (State Bar No. 165675)
Maura Prendiville (State Bar No. 257514)
LEGAL AID OF MARIN
30 N. San Pedro Road, Suite 220
San Rafael, CA 94903
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs Jacquelyn Hall,
Ariana Martinez, Karla Fernandez and Chavon White
Kevin K. Cholakian (State Bar No. 103423)
Colin H. Jewell (State Bar No. 122907)
CHOLAKIAN & ASSOCIATES
A Professional Corporation
400 Oyster Point Blvd., Ste. 415
South San Francisco, CA 94080
Telephone: [phone]
Facsimile: [phone]
http://www.lawyers.com/cholakian
Attorneys for Defendant Housing Authority of
The County of Marin

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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JACQUELYN HALL, ARIANA MARTINEZ,
KARLA FERNANDEZ and CHAVON
WHITE, for themselves and all others
similarly situated,
Plaintiffs,

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Case No.: C 12-04922 RS
STIPULATION (PROPOSED) RE CHANGES
TO SCHEDULING ORDER RE MOTIONS
AND DISCOVERY, AS MODIFIED BY THE
COURT

vs.
HOUSING AUTHORITY OF THE COUNTY
OF MARIN, and DOES 1 through 100,
INCLUSIVE,

Judge: Honorable Richard Seeborg
Date Action Filed: September 20, 2012
Trial Date: July 13, 2014

Defendants.

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SCHEDULING ORDER
U.S. DISTRICT COURT CASE NO. C 12-04922 RS

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Case3:12-cv-04922-RS Document44 Filed11/06/13 Page2 of 4

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The parties to the above-entitled action jointly submit this PROPOSED STIPULATION RE

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SCHEDULING DATES FOR MOTIONS AND DISCOVERY as requested by the Court when it

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reassigned Plaintiffs’ Motion to Compel and To Reschedule Motion for Class Certification to

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Magistrate Judge Corley. The parties negotiated preliminary changes, but had to await Judge

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Corley’s Order on the Motion to Compel for the Stipulation Could be finalized. Judge Corley held

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the hearing on the Motion to Compel on October 17, and issued her Order Granting in Part Motion

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to Compel on October 18. That Order required, in part, the parties to negotiate the terms of a notice

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to tenants regarding the production, and for Defendant to perform substantial work by October 30.

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As a result, the parties have been unable to finalize the instant Stipulation until now.

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The parties accordingly respectfully submit the following proposed changes to the Court’s

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initial Scheduling Order to take into account the effect of the productions ordered by Judge Corley,

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as modified by the parties’ subsequent agreements re production, and request that the Court confirm

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the terms of the Stipulation. (The parties have agreed that the dates set forth below for “Dispositive

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Motions” are the last possible date for the filing or hearing. The parties have also agreed, however,

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that the earliest either party can file the opening brief of a dispositive motion is February 22, the day

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after the last brief is due on the Class Certification Motion.)

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Scheduling

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Current Dates

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Rule 26 Exchanges

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Proposed New Dates

Fact Discovery

March 22, 2013

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Commencement

Jan. 15, 2013

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Conclusion

Nov. 27, 2013

March 28, 2014

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End Discovery Motions

Dec. 3, 2013

April 4, 2014

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Case Management

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Conference

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December 12, 2013, 10:00 a.m

SAME

Expert Discovery
Opening Reports Due

Jan. 10, 2014

April 4, 2014

SCHEDULING ORDER
U.S. DISTRICT COURT CASE NO. C 12-04922 RS

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Case3:12-cv-04922-RS Document44 Filed11/06/13 Page3 of 4

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Rebuttal Reports Due

Jan. 17, 2014

April 11, 2014

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Close of Motions

Jan. 31, 2014

April 24, 2014

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Class Certification

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Opening Brief

Aug. 16, 2013

Jan. 22, 2014

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Opposition

Sept. 6 2013

Feb. 14, 2014

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Reply

Sept. 18, 2013

Feb. 21, 2014

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Hearing

Oct. 3, 2013

March 6, 2014

Opening Briefs

Jan. 24, 2014

April 17, 2014

Opposition Briefs

Feb. 14, 2014

May 8, 2014

Reply Briefs

Feb. 27, 2014

May 21, 2014

Hearing

March 14, 2014

June 5, 2014

Pretrial Conference

July 3, 2014 at 10:00 a.m.

SAME

Trial Date

July 14, 2014 at 9:00 a.m.

SAME

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Dispositive Motions

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Dated: November 6, 2013

SOMMERS & SCHWARTZ, LLP

s/FFS_________________________________
By: Frank Sommers, Attorneys Plaintiffs
Jacquelyn Hall, Ariana Martinez, Karla
Fernandez and Chavon White

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SCHEDULING ORDER
U.S. DISTRICT COURT CASE NO. C 12-04922 RS

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Case3:12-cv-04922-RS Document44 Filed11/06/13 Page4 of 4

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Dated: November 6, 2013

CHOLAKIAN & ASSOCIATES
A Professional Corporation

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s/CHJ_________________________________
By: Colin H. Jewell, Attorneys for Defendant
Housing Authority of the County of Marin

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SO ORDERED

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11/8
Dated:_____________, 2013

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_____________________________________
Hon. Richard Seeborg
U.S. District Court Judge

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SCHEDULING ORDER
U.S. DISTRICT COURT CASE NO. C 12-04922 RS

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