Danscuk v. United Air Lines, Inc.

Filing 46

ORDER REGARDING JOINT DISCOVERY STATEMENT. Signed by Judge Elizabeth D Laporte on 8/23/2013. (knm, COURT STAFF) (Filed on 8/23/2013)

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BETH A. HUBER (SBN 184702)
THE HUBER LA W FIRM
807 E St.
San Rafael, California 94901
Telephone: [phone]
Facsimile:
[phone]
Email: [e-mail]
Attorneys for Plaintiff
CHRISTINE DANSCUK
DEBORAH 1. BROYLES (SBN 167681)
Email: [e-mail]
TIFFANY RENEE THOMAS (SBN 239085)
Email: [e-mail]
REED SMITH LLP
101 Second Street, Ste 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
UNITED AIR LINES, INC.

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UNITED STATES DISTRICT

COURT

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NORTHERN

DISTRICT

OF CALIFORNIA

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Plaintiff,

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CHRISTINE DANSCUK,

vs.
UNITED AIR LINES, INC., and DOES 1
through 10, inclusive,
Defendants.

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NO. C 12-5875 EDL
JOINT DISCOVERY STATEMENT
PURSUANT TO AUGUST 12,2013 COURT
ORDER

AND ORDER
Ctrm: E, 15th Fl.
Judge: Hon. Elizabeth D. Laporte

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Pursuant to this Court's August 12, 2013 Order Granting Defendant's

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Motion

to Continue

Mediation

Deadline,

Plaintiff

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Defendant United Air Lines, Inc. ("Defendant")

Christine

Danscuk

Administrative

("Plaintiff')

and

(together the "Parties") jointly submit this

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Joint Discovery Statement and Proposed Order
Case No. C 12-5875 EDL

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Proposed Discovery Order to the Court to supplement the previous Case Management Order in

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this case as to depositions only.

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THE PARTIES STIPULATE AND AGREE TO THE FOLLOWING:

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The June 5, 2013 Case Management and Pretrial Order permits each Party to take 10

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depositions in this matter prior to the discovery cut-off before trial and orders the parties to

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meet and confer regarding a limited number of depositions prior to mediation. Pursuant to the

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Court's August 12,2013 Order Granting Defendant's Administrative Motion to Continue

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Mediation Deadline and based on counsels' meet and confer discussion on August 15, 2013, the

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Parties agree to limit the number of depositions to be taken by either party prior to mediation to
three each.
Specifically, the parties have agreed to produce Plaintiff and three of Defendant's
witnesses for deposition during the last week of September 2013 or first week of October 2013.
The parties agree to the following deposition schedule:
Plaintiff: September 24, 2013
Jimmy Chiang: September 27,2013
Peter Haralabopoulos: October 1, 2013
Robert Smith: October 3,2013.
All other discovery, including special interrogatories, document requests and requests
for admissions remain as set forth in the June 5, 2013 Case Management and Pretrial Order.

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HUBER LAW FIRM

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By:

BETH A. HUBER
Attorney for Plaintiff
CHRISTINE DANSCUK

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;tIl7 (71 <{J:--

DATED: August 20, 2013

REED SMITH LLP
By:

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/s/ Tiffany Renee Thomas
DEBORAHJ.BROYLES
TIFF ANY RENEE THOMAS
Attorney for Defendants
UNITED AIRLINES INC

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Joint Discovery Statement and Proposed Order
Case No. C 12-5875 EDL

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IT IS SO ORDERED
The Discovery Plan as submitted above is hereby adopted by the Court in addition to the
Case Management and Pretrial Order for Jury Trial dated June 5, 2013.
DATED: August 23, 2013
ELIZABETH D. LAPORTE
United States Chief Magistrate Judge

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Joint Discovery Statement and Proposed Order
Case No. C 12-5875 EDL