O'Halloran et al v. GCA Services Group, Inc.

Filing 29

Scheduling Order by Hon. Haywood S Gilliam, Jr regarding 28 Stipulation.(hsglc3, COURT STAFF) (Filed on 8/4/2015)

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Angela M. Alioto, (SBN 130328)
Angela Mia Veronese, (SBN 269942)
Matthew J. Wayne, (SBN 283897)
LAW OFFICES OF MAYOR JOSEPH L. ALIOTO
AND ANGELA ALIOTO
700 Montgomery Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs Christopher O’Halloran,
Devon Oliver, and Davion McFarland
Jeremy T. Naftel, State Bar No. 185215
[e-mail]
Nicole A. Legrottaglie, State Bar No. 271416
[e-mail]
CAROTHERS DISANTE & FREUDENBERGER LLP
900 University Avenue
Suite 200
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant GCA Services Group of Texas, LP (erroneously sued as GCA Services
Group, Inc.)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
Christopher O’Halloran, Devon Oliver,
and Davion McFarland

) Case No.: 3:15-cv-00868-HSG
)
) PROPOSED SCHEDULING ORDER
)
Plaintiffs,
)
)
)
vs.
)
)
)
GCA Services Group, Inc., and DOES 1 to )
20,
)
)
)
Defendants.
)
______________________________________ )
O’Halloran et al. v. GCA Services Group of Texas, LP
PROPOSED SCHEDULING ORDER

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On June 9, 2015, the Parties’ counsel appeared before the Court for a Fed. R. Civ. P. 16
Case Management Conference. At the Case Management Conference, the Court indicated that
all fact discovery in this case should be completed by no later than January 15, 2016, motions to

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amend the complaint should be filed by June 23, 2015, and the first day of trial should be set

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two months or ten weeks from the dispositive motion hearing date. (Docket No. 25) The Court

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ordered the Parties’ counsel to meet and confer further concerning all other case management

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deadlines.

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The parties have met and conferred regarding the relevant dates and sought to structure a

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timeline permitting the parties to consider mediation after the court’s ruling on dispositive

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motions and before work on trial preparation begins in earnest.

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Defendant’s Position:
If the last day to hearing dispositive motions is March 31, 2016, a 60-day window

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between the ruling and the beginning of trial preparation would be approximately June 15.

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Allowing 30 days for trial preparation would yield a trial date of approximately July 15.

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However, lead trial counsel for Plaintiffs is out of the country from the beginning of July to

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mid-August. Thus, the trial date must be moved to early June or early September. Defendant’s

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position is that moving it to early June would make it difficult for the parties to hold a mediation

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after obtaining a ruling on dispositive motions and before beginning trial preparation.

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Defendant’s position is that moving it to early September would impose a modest delay but

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would have no other consequence.

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O’Halloran et al. v. GCA Services Group of Texas, LP
PROPOSED SCHEDULING ORDER

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Plaintiffs’ Position:
If the last day to hear dispositive motions is March 31, 2016, a 60-day window between
the hearing and the first day of trial would be approximately May 30, 2016.

A ten-week

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window would set the first day of trial for approximately June 9, 2016.

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Plaintiffs do not object to a September trial date. However, if the Court is inclined to set

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the trial date within sixty days or ten weeks of the dispositive motion hearing date, Plaintiffs

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request that the trial be set for no later than June 13, 2016, given that Plaintiffs’ lead trial

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counsel will be out of the country for most of July and August.
Accordingly, after having had met and conferred with each other, the Parties and their
counsel hereby suggest that the Court set the following case management deadlines:
Fact discovery cutoff:

January 15, 2016

Last day to disclose experts:

February 15, 2016

Last day to disclose rebuttal experts:

March 16, 2016

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Last day to hear dispositive motions:

March 31, 2016

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Last day to complete expert discovery:

June 3, 2016

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Final pretrial conference:

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June 6, 2016 or August 29, 2016

Trial:

June 13, 2016 or September 5, 2016

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Signed this

4th

day of

August

, 2015.

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Honorable Haywood S. Gilliam,
UNITED STATES DISTRICT JUDGE

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O’Halloran et al. v. GCA Services Group of Texas, LP
PROPOSED SCHEDULING ORDER

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Respectfully submitted,

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LAW OFFICES OF JOSEPH ALIOTO AND ANGELA
ALIOTO

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By:

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/s/ Matthew J. Wayne
Matthew J. Wayne
Attorneys for Plaintiffs

CAROTHERS DISANTE & FREUDENBERGER LLP

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By:

/s/ Nicole A. Legrottaglie
Nicole A. Legrottaglie
Attorneys for Defendant
GCA Services Group of Texas, LP

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LOCAL RULE 5-1 ATTESTATION

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In accordance with U.S. District Court for the Northern District of California Civil

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Local Rule 5-1(i)(3), the filing attorney attests that concurrence in the filing of this document

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has been obtained from each of the other Signatories, which shall serve in lieu of their

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signatures on the document.

The filing attorney will maintain records to support this

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concurrence for subsequent production for the Court, if so ordered, or for inspection upon

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request by a party, until one year after the final resolution of the action (including appeal, if

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any).

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Dated: June 30, 2015

LAW OFFICES OF JOSEPH ALIOTO AND ANGELA
ALIOTO

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By:

/s/ Matthew J. Wayne
Matthew J. Wayne
Attorneys for Plaintiffs

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O’Halloran et al. v. GCA Services Group of Texas, LP
PROPOSED SCHEDULING ORDER

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