Ogala et al v. Chevron Corporation et al

Filing 87

STIPULATION AND ORDER regarding discovery directed to new plaintiffs. Signed by Judge Samuel Conti on 6/23/2015. (sclc1, COURT STAFF) (Filed on 6/23/2015)

Case3:14-cv-00173-SC Document86 Filed06/18/15 Page1 of 3

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Robert A. Mittelstaedt (State Bar No. 60359)
[e-mail]
Caroline N. Mitchell (State Bar No. 143124)
[e-mail]
JONES DAY
555 California Street, 26th Floor
San Francisco, CA 94104
Telephone:
415.626.3939
Facsimile:
415.875.5700
Attorneys for Defendant
CHEVRON CORPORATION
Jacqueline Perry (State Bar No. 218367)
[e-mail]
Neil J. Fraser (State Bar No. 125651)
[e-mail]
RUFUS-ISAACS, ACLAND & GRANTHAM LLP
232 North Canon Drive
Beverly Hills, CA 90210
Telephone:
310.274.3803
Facsimile:
310.860.2430
Attorneys for Plaintiffs
NATTO IYELA GBARABE, et al.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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NATTO IYELA GBARABE, et al.,

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Plaintiffs,

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Case No. 14-cv-00173-SC
STIPULATION AND PROPOSED
ORDER RE DISCOVERY DIRECTED
TO NEW PLAINTIFFS IN THE
THIRD AMENDED COMPLAINT

v.
CHEVRON CORPORATION,

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Defendant.

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WHEREAS, defendant served the plaintiffs named in the Second Amended Complaint

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with one Set of Interrogatories and a First Set of Requests for Production, both dated February 17,

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2015 and a Second Set of Requests for Production, dated February 27, 2015 (hereafter the

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“Discovery”);

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///
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STIPULATION
CASE NO. 14-CV-00173-SC

Case3:14-cv-00173-SC Document86 Filed06/18/15 Page2 of 3

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WHEREAS, the Third Amended Complaint filed on June 1, 2015, among other things,

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lists 11 additional plaintiffs whom plaintiffs’ counsel contend were “drawn from the existing

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plaintiffs in this case;”

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WHEREAS, plaintiffs’ counsel offered that they would treat the Discovery as if it were

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served on those 11 persons on June 1, 2015, without the need for defendant to re-serve the

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Discovery, and defendant accepted that offer without prejudice to its response to the Third

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Amended Complaint and without conceding its propriety,

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Now, therefore, the parties hereby stipulate as follows:

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1. The Discovery identified above shall be deemed served as of June 1, 2015, on the 11

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individuals referred to above.
2. This is without prejudice to defendant’s rights and remedies with respect to filing of

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the Third Amended Complaint and without prejudice to plaintiffs’ position that the 11 plaintiffs

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were named pursuant to stipulation dated March 15, 2015.

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Pursuant to Local Rule 5-1(i)(3), I, Robert A. Mittelstaedt, attest that concurrence in filing

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this document has been obtained from the other signatory.

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Dated: June 18, 2015

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By: /s/ Robert A. Mittelstaedt
Robert A. Mittelstaedt

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Counsel for Defendant
CHEVRON CORPORATION

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Jones Day

Dated: June 18, 2015

Rufus-Isaacs, Acland & Grantham LLP
By: /s/ Jacqueline Perry
Jacqueline Perry
Counsel for Plaintiffs
NATTO IYELA GBARABE, et al.

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STIPULATION
CASE NO. 14-CV-00173-SC

Case3:14-cv-00173-SC Document86 Filed06/18/15 Page3 of 3

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[PROPOSED] ORDER

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PURSUANT TO THIS STIPULATION, IT IS SO ORDERED.

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June 23, 2015
Dated: ________________

_____________________________
The Honorable Samuel Conti

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NAI-1500377837

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STIPULATION
CASE NO. 14-CV-00173-SC