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

Filing 109

ORDER TO STAY DISCOVERY AND CONTINUE THE PRETRIAL SCHEDULE granting, as modified, 108 STIPULATION. Close of Fact Discovery: 1/8/2018. Dispositive Motion to be heard by 7/13/2018. Pretrial Conference set for 9/17/2018 02:00 PM and Jury Trial set for 11/13/2018 08:30 AM in Courtroom 2, 17th Floor, San Francisco before Hon. William H. Orrick. Signed by Judge William H. Orrick on 06/30/2017. (jmdS, COURT STAFF) (Filed on 6/30/2017)

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]
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[e-mail]
[e-mail]
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Attorneys for Plaintiffs
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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]

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CHARLES F. ROBINSON (SBN 113197)
[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]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

SOFIE KARASEK, individually;
21 NICOLETTA COMMINS, individually;
ARYLE BUTLER, individually,
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Plaintiffs,
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vs.
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THE REGENTS OF THE UNIVERSITY OF
25 CALIFORNIA, a public entity, and DOES 1
through 100, inclusive,
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Defendants.
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Case No. 3:15-cv-03717-WHO
STIPULATION AND ORDER TO STAY
DISCOVERY AND CONTINUE THE
PRETRIAL SCHEDULE
Judge: Hon. William H. Orrick

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STIPULATION AND ORDER TO CONTINUE THE PRETRIAL SCHEDULE

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

4 No. 83), Defendant moved to dismiss Plaintiffs Karasek’s and Commins’s claims on October 3,
5 2016 (Dkt. No. 87), and the Court granted the motion to dismiss without leave to amend on
6 December 22, 2016 (Dkt. No. 96);
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WHEREAS, on February 23, 2017, this Court ordered the below pretrial schedule (Dkt. No.

8 103);
WHEREAS, the parties met and conferred regarding ADR and agreed to engage in private

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10 mediation by June 30, 2017, and the Court subsequently ordered mediation by this date (Dkt. No.
11 104);
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WHEREAS, the parties scheduled a mediation with Michael Moorhead of Judicate West to

13 occur on June 30, 2017;
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WHEREAS, in late June 2017, Mr. Moorhead’s office informed the parties that he would

15 need to postpone the mediation until September 2017 due to medical reasons;
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WHEREAS, the parties are in the process of determining an alternate date in September

17 2017 for the mediation with Mr. Moorhead;
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WHEREAS, these pretrial deadlines were previously modified once by the stipulation and

19 order entered on February 23, 2017 (Dkt. No. 23); and
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WHEREAS, a stay of discovery and four-month extension of the pretrial deadlines would

21 enable the parties participate in Private ADR with the agreed upon mediator.
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IT IS HEREBY STIPULATED between Plaintiffs and Defendant, by and through their

23 undersigned attorneys, that the pretrial dates shall be extended by approximately 4 months as
24 follows, and all discovery shall be stayed through and until mediation in this case:
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Event

Current Date

Stipulated Date

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Private ADR deadline

June 30, 2017

October 30, 2017

Fact discovery cutoff

September 8, 2017

January 8, 2018

Expect disclosure

October 20, 2017

February 20, 2018

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

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Expert rebuttal

November 17, 2017

March 16, 2018

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Expert discovery cutoff

January 4, 2018

May 4, 2018

Dispositive motions heard by

March 7, 2018

July 13, 2018

Pretrial Conference

May 14, 2018 at 2:00pm

September 17, 2018, at 2:00pm

Trial

June 4, 2018 at 8:30am

October 8, 2018, at 8:30am

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Respectfully submitted,
7 DATED: June 28, 2017
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By:

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

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

DATED: June 28, 2017

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

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By:

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

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ORDER

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23 PURSUANT TO STIPULATION, IT IS SO ORDERED, as modified below:
Trial Date: November 13, 2018 at 8:30 a.m.
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25 Dated: June 30, 2017
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WILLIAM H. ORRICK
UNITED STATES DISTRICT JUDGE

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-33:15-cv-03717-WHO
STIPULATION AND ORDER TO CONTINUE THE PRETRIAL SCHEDULE

ATTESTATION CLAUSE

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

3 obtained from the above signatories.
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Dated: June 28, 2017

By:

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

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-43:15-cv-03717-WHO
STIPULATION AND ORDER TO CONTINUE THE PRETRIAL SCHEDULE