Karasek et al v. Regents of the University of California, The

Filing 103

ORDER granting 102 STIPULATION to Continue the Pretrial Schedule. Close of Fact Discovery: 9/8/2017. Dispositive Motions to be heard by 3/7/2018. Pretrial Conference set for 5/14/2018 02:00 PM and Jury Trial set for 6/4/2018 08:30 AM in Courtroom 2, 17th Floor, San Francisco before Hon. William H. Orrick. Signed by Judge William H. Orrick on 02/23/2017. (jmdS, COURT STAFF) (Filed on 2/23/2017)

IRWIN M. ZALKIN, ESQ. (SBN 89957)
1 DEVIN M. STOREY, ESQ. (SBN 234271)
ALEXANDER S. ZALKIN, ESQ. (SBN 280813)
2 RYAN M. COHEN, ESQ, (SBN 261313)
The Zalkin Law Firm, P.C.
3 12555 High Bluff Drive, Suite 301
San Diego, CA 92130
4 Tel: [phone]
Fax: [phone]
5 Email: [e-mail]
[e-mail]
6
[e-mail]
[e-mail]
7
Attorneys for Plaintiffs
8

BRADLEY S. PHILLIPS (SBN 85263)
[e-mail]
HAILYN J. CHEN (SBN 237436)
[e-mail]
SARA N. TAYLOR (SBN 288573)
[e-mail]
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue, Thirty-Fifth Floor
Los Angeles, California 90071-1560
Telephone:
[phone]
Facsimile:
[phone]
JESLYN A. EVERITT (SBN 274701)
[e-mail]
MUNGER, TOLLES & OLSON LLP
560 Mission Street, Twenty-Seventh Floor
San Francisco, California 94105-2907
Telephone:
[phone]
Facsimile:
[phone]

9
10

17

CHARLES F. ROBINSON (SBN 113197)
[e-mail]
KAREN J. PETRULAKIS (SBN 168732)
[e-mail]
MARGARET L. WU (SBN 184167)
[e-mail]
SONYA SANCHEZ (SBN 247541)
[e-mail]
UNIVERSITY OF CALIFORNIA
Office of the General Counsel
1111 Franklin Street, 8th Floor
Oakland, CA 94607-5200
Telephone:
[phone]
Facsimile:
[phone]

18

Attorneys for Defendants

11
12
13
14
15
16

19

UNITED STATES DISTRICT COURT

20

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

21 SOFIE KARASEK, individually;
NICOLETTA COMMINS, individually;
22 ARYLE BUTLER, individually,
23
24

Case No. 3:15-cv-03717-WHO
STIPULATION AND ORDER TO
CONTINUE THE PRETRIAL SCHEDULE

Plaintiffs,
Judge: Hon. William H. Orrick
vs.

25 THE REGENTS OF THE UNIVERSITY OF
CALIFORNIA, a public entity, and DOES 1
26 through 100, inclusive,
27

Defendants.

28
-1STIPULATION AND ORDER TO CONTINUE THE PRETRIAL SCHEDULE

1

Pursuant to Local Rule 6-2, the parties to the above entitled action, by and through their

2 respective counsel of record, hereby stipulate as follows:
3

WHEREAS, the Court set the below pretrial schedule at the Case Management Conference on

4 July 5, 2016 (Dkt. No. 72);
WHEREAS, thereafter on July 28, 2016, the Court dismissed Plaintiffs Sofie Karasek’s and

5

6 Nicoletta Commins’s claims in the Third Amended Complaint with leave to amend (Dkt. No. 77);
7

WHEREAS, Plaintiffs filed their Fourth Amended Complaint on September 1, 2016 (Dkt.

8 No. 83), Defendant moved to dismiss Plaintiffs Karasek’s and Commins’s claims on October 3, 2016
9 (Dkt. No. 87), and the Court granted the motion to dismiss without leave to amend on December 22,
10 2016 (Dkt. No. 96);
11

WHEREAS, the Parties did not anticipate the additional round of motion to dismiss briefing

12 when they proposed the pretrial schedule that was adopted by the Court (see Dkt. No. 69);
13

WHEREAS, the discovery cut-off (March 10, 2017) and other pretrial deadlines do not provide

14 adequate time for the Parties to respond to written discovery requests, produce and review documents,
15 serve third party subpoenas, conduct depositions, attempt mediation, and engage in other discovery
16 efforts necessary for the development of their respective cases;
17

WHEREAS, these pretrial deadlines have not been previously modified;

18

WHEREAS, a six-month extension of the pretrial deadlines would enable the parties to take

19 the necessary discovery.
20

IT IS HEREBY STIPULATED between Plaintiffs and Defendant, by and through their

21 undersigned attorneys, that the pretrial dates shall be extended by approximately 6 months as follows:
22

Event

Current Date

Stipulated Date

23

Fact discovery cutoff

March 10, 2017

September 8, 2017

Expect disclosure

April 28, 2017

October 20, 2017

Expert rebuttal

May 26, 2017

November 17, 2017

Expert discovery cutoff

June 30, 2017

January 4, 2018

26

Dispositive motions heard by

September 6, 2017

March 7, 2018

27

Pretrial Conference

November 13, 2017 at 2:00pm

May 14, 2018 at 2:00pm

28

Trial

December 11, 2017 at 8:30am

June 11, 2018 at 2:00pm

24
25

-23:15-cv-03717-WHO
STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE PRETRIAL SCHEDULE

1

Respectfully submitted,

2
3

DATED: February 21, 2017

4
5

MUNGER, TOLLES & OLSON LLP
BRADLEY S. PHILLIPS
HAILYN J. CHEN
JESLYN A. EVERITT
SARA N. TAYLOR

6
7

By:

/s/ Jeslyn A. Everitt
JESLYN A. EVERITT
Attorneys for Defendant

8
9
10
11 DATED: February 21, 2017
12
13

THE ZALKIN LAW FIRM
IRWIN M. ZALKIN
DEVIN M. STOREY
ALEXANDER S. ZALKIN
RYAN M. COHEN

14
15

By:

/s/ Alexander S. Zalkin
ALEXANDER S. ZALKIN
Attorneys for Plaintiffs

16
17
18
19

ORDER

20

21 PURSUANT TO STIPULATION, IT IS SO ORDERED with the modification that the trial will
commence at 8:30 a.m. on June 4, 2018.
22
23 Dated: February 23, 2017
24

WILLIAM H. ORRICK
UNITED STATES DISTRICT JUDGE

25
26
27
28
-33:15-cv-03717-WHO
STIPULATION AND ORDER TO CONTINUE THE PRETRIAL SCHEDULE

ATTESTATION CLAUSE

1
2

I attest under penalty of perjury that concurrence in the filing of this document has been

3 obtained from the above signatories.
4
5
6

Dated: February 21, 2017

By:

/s/ Jeslyn A. Everitt
Jeslyn A. Everitt
Attorneys for Defendant

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-43:15-cv-03717-WHO
STIPULATION AND ORDER TO CONTINUE THE PRETRIAL SCHEDULE