K.H. v. Secretary of the Department of Homeland Security

Filing 28

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)

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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 4 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 5 Telephone: (415) 436-6475 FAX: (415) 436-7234 6 wendy.garbers@usdoj.gov 7 Attorneys for Defendant SECRETARY OF 8 THE DEPARTMENT OF HOMELAND SECURITY 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 14 15 16 17 18 K.H., on behalf of himself and those similarly situated, ) ) ) Plaintiff, ) ) v. ) ) THE SECRETARY OF THE DEPARTMENT ) OF HOMELAND SECURITY, ) ) Defendant. ) Case No. 15-cv-02740 JST JOINT PROPOSAL REGARDING SCHEDULE AND [PROPOSED] ORDER The Honorable Jon S. Tigar 19 20 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: 22 SCHEDULE EVENT DATE 23 24 25 26 27 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 30 1 1 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 1 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. 11 12 DATED: November 23, 2015 Respectfully submitted, 13 BRIAN J. STRETCH Acting United States Attorney 14 /s/ Wendy M. Garbers WENDY M. GARBERS Assistant United States Attorney Attorneys for Defendant 15 16 17 DATED: November 23, 2015 MORRIS POLICH & PURDY LLP 18 19 /s/ Nicholas M. Wieczorek * NICHOLAS M. WIECZOREK Attorneys for Plaintiff 20 21 *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. 23 24 25 1 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 26 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 30 2 [PROPOSED] ORDER 1 2 3 Pursuant to the parties’ joint proposal, IT IS SO ORDERED. 4 5 Dated: November 30, 2015 6 7 THE HONORABLE JON S. TIGAR 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOINT PROPOSAL REGARDING SCHEDULE AND [PROPOSED] ORDER NO. 15-CV-02740 JST 30 3

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