Eileen Brown et al v. Freedom West Homes, Inc. et al

Filing 148

STIPULATION AND ORDER re 147 Regarding Discovery< cut off deadline filed by Eileen Brown Discovery due by 6/22/2018. Signed by Judge Edward M. Chen on 6/7/18. (bpfS, COURT STAFF) (Filed on 6/7/2018)

1 Yosef Peretz (SBN 209288)
[e-mail]
2 Ruth L. Israely (SBN 289586)
[e-mail]
3 PERETZ & ASSOCIATES
22 Battery Street, Suite 200
4 San Francisco, CA 94111
Telephone: [phone]
5 Facsimile: [phone]
6 Jean Hyams (SBN 144425)
[e-mail]
7 Sharon Vinick (SBN 129914)
[e-mail]
8 LEVY VINICK BURRELL HYAMS LLP
180 Grand Avenue, Suite 1300
9 Oakland, CA 94612
Telephone: [phone]
10 Facsimile: [phone]
11 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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EILIEEN BROWN, et al.

Case No. 3:15-cv-04874-EMC

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Plaintiffs,
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STIPULATION AND [PROPOSED]
ORDER REGARDING DISCOVERY

vs.
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FREEDOM WEST HOMES, INC., et al.
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Defendants.
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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY
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Plaintiffs EILEEN BROWN, PRENTISS BELTON, MICHELLE HARRIS, EVELYN

2 JONES-MACGLAUN, ETHEL BENSON, KEISHA FINLEY, KEISHA JONES, DOROTHA
3 GRAHAM, BARBARA KERLEGAN, CORINNE HARPER, DEENA PERKINS, LESSIE
4 BROWN, SABRINA PARISH, ELLYN GINDEN-COOPER, TANYA TWYMAN, ZELPHIA
5 CONNOR, ANTOINETTE BLUE and LASHAWN JEFFRIES (collectively, “Plaintiffs”), and
6 Defendant FREEDOM WEST HOMES (“FWH”), ALTON MANAGEMENT CORPORATION
7 (“Alton”), WILLIAM HUTTON (“Hutton”), RAYMOND BROWN (“R. Brown”) and ANASON
8 WON PAK (“Pak”) (Plaintiffs, Alton, Hutton, R. Brown, Pak and FWH are referred to collectively
9 as the “Parties”) through their respective counsel of record, hereby stipulate as follows:
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WHEREAS the Trial date in this matter remains November 5, 2018;

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WHEREAS the Parties have worked collaboratively to create a mutually agreeable

12 deposition schedule in this case that accommodated the schedules of counsel as well as the
13 unusually numerous Plaintiffs, Defendants, and witnesses;
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WHEREAS Parties, witnesses, and counsel for the Parties have had numerous conflicts

15 including trial schedules in other cases that have not permitted the depositions to take place prior to
16 the close of discovery set for May 26, 2018;
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The Parties have agreed that, subject to the court’s entry of an order pursuant to this

18 stipulation, the remaining plaintiffs’ depositions shall be taken prior to the date set for mediation,
19 June 14, 2018, and the date for the close of non-expert discovery shall be modified such that non20 expert discovery shall close on June 22, 2018. All other dates set by the court remain unchanged.
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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY
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1 Dated: June 5, 2018
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PERETZ & ASSOCIATES
By: (-) Yosef Peretz
Yosef Peretz
Attorneys for Plaintiffs

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Dated: June 5, 2018
5 CLARK HILL LLP,
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By: (-) Sara B. Allman
Sara B. Allman
Attorneys for Defendants
ALTON MANAGEMENT CO. and
WILLIAM HUTTON

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9 Dated: June 5, 2018
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NIXON PEABODY
By: (-) Neal P. Gauger
Neal P. Gauger
Attorneys for Defendants
RAYMOND BROWN and
FREEDOM WEST HOMES, INC.

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Dated: June 5, 2018

HINSHAW & CULBERTSON LLP

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By: (-) David Ian Dalby
David Ian Dalby
Attorneys for Defendant
ANASON WON PAK

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I attest that concurrence in the filing of the document has been obtained from the above
signatories.

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21 Dated: June 5, 2018

PERETZ & ASSOCIATES

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By: (-) Yosef Peretz
Yosef Peretz
Attorneys for Plaintiffs

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY
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[PROPOSED] ORDER

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Pursuant to the Parties’ stipulation, and good cause appearing therefore, the Court hereby

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orders that the remaining plaintiffs’ depositions shall be taken prior to the date set for mediation,
June 14, 2018, and the date for the close of non-expert discovery shall be modified such that nonexpert discovery shall close on June 22, 2018. All other dates set by the Court remain unchanged.

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By: ____________________________________
n
M. Che
Edward
Judge
HON. EDWARD M. CHEN

FO

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RT

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6/7/2018

NO

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DERED

O OR
IT IS S

R NIA

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UNIT
ED

IT IS SO ORDERED.

S DISTRICT
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UNITED STATES DISTRICT COURT JUDGE

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY
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