Civil Rights Education and Enforcement Center et al v. Hospitality Properties Trust

Filing 121

STIPULATION AND ORDER re 120 STIPULATION WITH PROPOSED ORDER. Motion Hearing set for 8/2/2018 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor before Judge Jon S. Tigar. Signed by Judge Jon S. Tigar on February 15, 2018. (wsn, COURT STAFF) (Filed on 2/15/2018)

Timothy P. Fox – Cal. Bar No. 157750
CIVIL RIGHTS EDUCATION AND
ENFORCEMENT CENTER
104 Broadway, Suite 400
Denver, CO 80203
[phone]
[e-mail]

Bill Lann Lee – Cal. Bar No. 108452
CIVIL RIGHTS EDUCATION AND
ENFORCEMENT CENTER.
2120 University Ave.
Berkeley, CA 94704
[phone]
[e-mail]

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Julia Campins – Cal. Bar No. 238023
Hillary Benham-Baker – Cal. Bar No.
265019
CAMPINS BENHAM-BAKER
935 Moraga Road, Suite 200
Lafayette, CA 94549
[phone]
[e-mail]
[e-mail]

Linda Dardarian – Cal Bar No. 131001
Andrew P. Lee – Cal. Bar No. 245903
GOLDSTEIN, BORGEN, DARDARIAN & HO
300 Lakeside Drive, Suite 1000
Oakland, CA 94612
[phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiffs

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[Additional Appearances on Next Page]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Case No. 3:15-cv-00221-JST

THE CIVIL RIGHTS EDUCATION AND
ENFORCEMENT CENTER, on behalf of
itself, and ANN CUPOLO FREEMAN,
RUTHEE GOLDKORN, and JULIE
REISKIN, on behalf of themselves and a
proposed class of similarly situated
persons,

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v.

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The Honorable Jon S. Tigar
CMC Date: February 21, 2018
CMC Time: 2:00 p.m.

Plaintiffs,

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[PROPOSED] ORDER ON STIPULATION
RE: CASE SCHEDULE

HOSPITALITY PROPERTIES TRUST,

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Defendant.

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[PROPOSED] ORDER ON STIPULATION

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CASE NO. 3:15-CV-00221-JST

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OGLETREE, DEAKINS,
NASH, SMOAK & STEWART, P.C.
David Raizman (State Bar No. 129407)
Christopher F. Wong (State Bar No. 142507)
400 South Hope Street, Suite 1200
Los Angeles, California 90071
[phone]
[e-mail]
[e-mail]
Attorneys for Defendant
Hospitality Properties Trust

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[PROPOSED] ORDER ON STIPULATION

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CASE NO. 3:15-CV-00221-JST

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PURSUANT TO THE STIPULATION OF THE PARTIES, filed on February 14, 2018,
and good cause shown, IT IS HEREBY ORDERED:
1.

With respect to the review of HPT emails referenced in the Stipulation, HPT

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shall conduct its review for responsive documents requested by Plaintiffs after first utilizing an

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electronic document management system to eliminate duplicates and to conduct a file search

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identifying those emails that contain (i) the domain name of any management company at

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HPT’s U.S. hotels (e.g., “marriott.com,” “wyn.com,” “ihg.com,” “hyatt.com,”
“carlsonrezidor.com,” and “sonesta.com”), and (ii) any of the terms “bus,” “van,” “shuttle,”
“ADA,” “Americans with Disabilities Act,” or “transportation” (or, where applicable, the plural
forms of those terms). HPT shall produce its documents on a rolling basis, and shall complete
the production of documents to Plaintiffs by May 4, 2018.
2.

Plaintiffs shall conduct the Rule 30(b)(6) deposition described above by no later

than May 25, 2018.
3.

HPT shall file and serve its proposed motion for summary judgment by no later

than June 1, 2018. Plaintiffs shall file and serve their opposition by June 22, 2018, and HPT
shall file and serve its reply by July 6, 2018.
4.

In accordance with the Court’s request for three proposed dates for the hearing

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on HPT’s motion for summary judgment, the parties propose the following dates: July 12, 19 or

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26, 2018.

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5.

Plaintiffs shall file and serve their proposed motion to amend the First Amended

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Complaint (if applicable) by no later than 20 days after the Court’s ruling on HPT’s motion for

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summary judgment.

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IT IS SO ORDERED.
February 15, 2018
Dated: _____________________

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UNITED STATES DISTRICT JUDGE

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32992415.1

[PROPOSED] ORDER ON STIPULATION

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CASE NO. 3:15-CV-00221-JST