Sran v. Regents of the University of California

Filing 38

STIPULATION AND ORDER re 37 STIPULATION WITH [PROPOSED] ORDER Continuing Expert Disclosure and Expert Discovery Deadlines filed by Regents of the University of California. Signed by Judge Jon S. Tigar on February 28, 2017. (wsn, COURT STAFF) (Filed on 2/28/2017)

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MICHAEL D. BRUNO (SBN: 166805)
[e-mail]
ALYSON S. CABRERA (SBN 222717)
[e-mail]
JENNIFER M. LYNCH (SBN 272976)
[e-mail]
GORDON & REES
SCULLY MANSUKHANI LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
REGENTS OF THE UNIVERSITY OF CALIFORNIA

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UNITED STATE DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO

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KULGINDER SRAN,

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Plaintiff,

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vs.
REGENTS OF THE UNIVERSITY OF
CALIFORNIA

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Defendants.

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Case No. C-15-4471-JST
STIPULATION AND [PROPOSED]
ORDER CONTINUING EXPERT
DISCLOSURE AND EXPERT
DISCOVERY DEADLINES
Complaint Filed: September 30, 2015

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RECITALS

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WHEREAS the parties have exchanged written discovery and substantial documents in

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the case, and otherwise diligently worked together to move the case forward with respect to

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discovery and the scheduling of depositions;

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WHEREAS Plaintiff’s deposition (two sessions) was completed on January 10, 2017;

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WHEREAS the deposition of Dr. Linda Centore is scheduled to take place on February

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24, 2017;

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STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST
MAST

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WHEREAS two other witness depositions are currently pending and in the process of
being scheduled;

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WHEREAS the parties participated in mediation with Hon. Justice Lambden on
November 15, 2016;

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WHEREAS the parties are still in communication regarding potential settlement;

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WHEREAS the current expert disclosure deadline is March 6, 2017;

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WHEREAS the current expert discovery cutoff deadline is April 10, 2017;

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WHEREAS the parties are still in the process of conducting additional fact discovery

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including written discovery, document production and witness depositions;

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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WHEREAS the parties desire to conclude fact discovery before engaging in expert
witness discovery;

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WHEREAS the parties need additional time in order to meaningfully conduct expert
witness discovery;

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WHEREAS the parties are still in the process of engaging in settlement discussions and

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desire to determine whether informal resolution is possible before expending significant time and

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expense conducting expert witness discovery;

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WHEREAS the parties respectfully request that the Court continue the current expert

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discovery deadlines as outlined by the parties below, or as soon thereafter as the Court is

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available. Alternatively, the parties request a CMC to further discuss these issues with the Court.

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STIPULATION

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THEREFORE, IT IS HEREBY STIPULATED THAT the expert disclosure and expert

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STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST

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discovery cutoff deadlines are continued as follows:

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Event
Expert Disclosure Deadline
Expert rebuttal
Expert Discovery Cutoff

Current Date
March 6, 2017
None set.
April 10, 2017

Proposed Date
April 10, 2017
May 1, 2017
May 15, 2017

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Dated: February 24, 2017

GORDON & REES
SCULLY MANSUKHANI LLP

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By:

/s/ Jennifer M. Lynch
JENNIFER M. LYNCH
Attorney for Defendant
REGENTS OF THE UNIVERSITY OF
CALIFORNIA

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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Dated: February 24, 2017

LEIGH LAW GROUP
By:

/s/ Jay Jambeck
Jay Jambeck
Attorney for Plaintiff
KULGINDER SRAN

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[PROPOSED] ORDER
According to the parties’ stipulation, and good cause appearing, it is hereby ordered that
the expert disclosure and expert discovery cutoff deadlines of this matter are hereby continued as
follows:

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Event
Expert Disclosure Deadline
Expert rebuttal
Expert Discovery Cutoff

Current Date
March 6, 2017
None set.
April 10, 2017

Proposed Date
April 10, 2017
May 1, 2017
May 15, 2017

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1112749/31740760v.1

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IT IS SO ORDERED.
Dated: February 28, 2017

___________________________________
Hon. Jon S. Tigar
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STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST