K.H. v. Secretary of the Department of Homeland Security
Filing
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STIPULATION AND ORDER re 27 STIPULATION WITH PROPOSED ORDER Re Case Schedule filed by Secretary of the Department of Homeland Security. Start of Fact Discovery 12/1/2015. Amended Complaint due 1/15/2016. Response to Amended Compl aint due 2/15/2016. Telephonic Case Management Conference set for 4/27/2016 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Plaintiff's Class Experts due 5/2/2016. Defendant's Class Experts due 7/1/2016. Deadline for Class Expert Depositions 9/1/2016. Deadline for Plaintiff's Class Certification Motion 10/6/2016. Responses due 11/3/2016. Replies due 12/1/2016. Class Certification Motion Hearing set for 12/15/2016 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco before Hon. Jon S. Tigar. Signed by Judge Jon S. Tigar on November 30, 2015. (wsn, COURT STAFF) (Filed on 11/30/2015)
1 BRIAN J. STRETCH (CABN 163973)
Acting United States Attorney
2 ALEX G. TSE (CABN 152348)
Chief, Civil Division
3 WENDY M. GARBERS (CABN 213208)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
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Telephone: (415) 436-6475
FAX: (415) 436-7234
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wendy.garbers@usdoj.gov
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Attorneys for Defendant SECRETARY OF
8 THE DEPARTMENT OF HOMELAND
SECURITY
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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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K.H., on behalf of himself and those similarly
situated,
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Plaintiff,
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v.
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THE SECRETARY OF THE DEPARTMENT )
OF HOMELAND SECURITY,
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Defendant.
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Case No. 15-cv-02740 JST
JOINT PROPOSAL REGARDING SCHEDULE
AND [PROPOSED] ORDER
The Honorable Jon S. Tigar
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Pursuant to the Court’s instruction, the parties to the above-captioned action jointly submit the
21 proposed case schedule, through the class certification hearing:
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SCHEDULE EVENT
DATE
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Start of Fact Discovery
December 1, 2015
Deadline for Plaintiff to File Amended Complaint
January 15, 2016
Defendant’s Response to Amended Complaint Due
February 15, 2016
Telephonic Further Case Management Conference
April 27, 2016, at 2:00 p.m.
Plaintiff’s Disclosures Re Class Cert Experts Due
28 (FRCP 26(a)(2))
May 2, 2016
JOINT PROPOSAL REGARDING SCHEDULE AND [PROPOSED] ORDER
NO. 15-CV-02740 JST
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Defendant’s Disclosures Re Class Cert Experts Due
2 (FRCP 26(a)(2))
July 1, 2016
3 Deadline for Class Cert Expert Depositions
September 1, 2016
4 Filing Deadline for Plaintiff’s Class Certification
Motion (under seal, redacted version filed within 30
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5 days)
October 6, 2016
6 Filing Deadline for Defendant’s Class Certification
Opposition (under seal, redacted version filed within
7 30 days)
November 3, 2016
8 Filing Deadline for Plaintiff’s Class Certification
Reply (under seal, redacted version filed within 30
9 days)
December 1, 2016
10 Hearing on Class Certification Motion
December 15, 2016 at 2:00 p.m.
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12 DATED: November 23, 2015
Respectfully submitted,
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BRIAN J. STRETCH
Acting United States Attorney
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/s/ Wendy M. Garbers
WENDY M. GARBERS
Assistant United States Attorney
Attorneys for Defendant
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DATED: November 23, 2015
MORRIS POLICH & PURDY LLP
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/s/ Nicholas M. Wieczorek *
NICHOLAS M. WIECZOREK
Attorneys for Plaintiff
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*In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of perjury
22 that plaintiff has concurred in the filing of this document.
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Many of the documents regarding the Federal Air Marshal Service’s operations contain
Sensitive Security Information (“SSI”), as defined by federal regulation, 49 C.F.R. § 1520.5. TSA has a
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SSI Program Office that reviews court filings for SSI redaction. See generally 49 C.F.R. § 1520.5.
27 Otherwise, “records containing SSI are not available for public inspection or copying.” 49 C.F.R.
§ 1520.15. In order to protect this SSI, the parties request that they initially be permitted to file their
28 class certification briefing under seal. Both sides’ briefs will then be reviewed by the SSI Program
Office for redactions, and publicly-available versions filed within 30 days.
JOINT PROPOSAL REGARDING SCHEDULE AND [PROPOSED] ORDER
NO. 15-CV-02740 JST
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[PROPOSED] ORDER
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Pursuant to the parties’ joint proposal, IT IS SO ORDERED.
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5 Dated: November 30, 2015
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THE HONORABLE JON S. TIGAR
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JOINT PROPOSAL REGARDING SCHEDULE AND [PROPOSED] ORDER
NO. 15-CV-02740 JST
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