Kelly v. Bay Area Toll Authority et al

Filing 27

STIPULATION AND ORDER RE 26 to Continue Dates in the Court's January 27, 2017 Order Requiring Parties to Meet and Confer. Signed by Judge Richard Seeborg on 2/7/17. (clS, COURT STAFF) (Filed on 2/7/2017)

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LAFAYETTE & KUMAGAI LLP
GARY T. LAFAYETTE (SBN 88666)
REBECCA K. KIMURA (SBN 220420)
MELISSA A. DUBBS (SBN 163650)
1300 Clay Street, Suite 810
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
XEROX STATE & LOCAL SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Plaintiff,

FAX

[phone]
[phone]

600
94105

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SAN FRANCISCO, CALIFORNIA

MISSION STREET, SUITE

ATTORNEYS AT LAW

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MICHELLE KELLY, an individual, on
behalf of herself and those similarly
situated,

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LAFAYETTE & KUMAGAI LLP

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BAY AREA TOLL AUTHORITY;
GOLDEN GATE BRIDGE, HIGHWAY
AND TRANSPORTATION DISTRICT;
XEROX STATE AND LOCAL
SOLUTIONS, INC.; and DOES 1-100,

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STIPULATION AND [PROPOSED] ORDER
TO CONTINUE DATES IN THE COURT’S
JANUARY 27, 2017 ORDER REQUIRING
PARTIES TO MEET AND CONFER

v.

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Case No. 3:16-cv-06837-RS

Defendants.

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Action Filed: September 7, 2016
Action Removed: November 28, 2016

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DATES IN THE COURT’S JANUARY
27, 2017 ORDER REQUIRING PARTIES TO MEET AND CONFER (Case No. 3:16-cv-06837)

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STIPULATION AND REQUEST

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Plaintiff Michelle Kelly (“Plaintiff”) and Defendants XEROX STATE AND LOCAL

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SOLUTIONS, INC. (“Xerox”), BAY AREA TOLL AUTHORITY ("BATA") and GOLDEN

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GATE BRIDGE, HIGHWAY AND TRANSPORTATION DISTRICT ("the District")

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(collectively “Defendants”) (collectively referred to as the “Parties”) through their respective

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counsel hereby stipulate as follows:

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FAX

[phone]
[phone]

600
94105

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SAN FRANCISCO, CALIFORNIA

MISSION STREET, SUITE

ATTORNEYS AT LAW

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101

LAFAYETTE & KUMAGAI LLP

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WHEREAS, on January 18, 2017, Xerox filed a letter with the Court requesting guidance
on a discovery dispute with Plaintiff;
WHEREAS, on January 20, 2017, Plaintiff filed a letter with the Court in response;
WHEREAS, on January 27, 2017, the Court issued an Order Requiring Parties to Meet
and Confer over the items in the discovery letters (the “Order”);
WHEREAS, paragraph 2 of the Order requires the Parties to meet and confer and file a
joint supplemental letter reflecting the results of those efforts by February 8, 2017;
WHEREAS, pursuant to the Order, the Parties met and conferred by telephone on January

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30, 2017, February 2, 2017 and February 6, 2017 over the items in Xerox’s and Plaintiff’s

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discovery letters;

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WHEREAS, the Parties are continuing to meet and confer and have scheduled another
call for February 10, 2017 to discuss the items in their discovery letters;
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties through

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their respective attorneys of record that the deadline to file a joint supplemental letter reflecting

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the results of the Parties’ meet and confer efforts be extended for one week to February 15, 2017.

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DATED: February 7, 2017

LINDEMANN LAW FIRM, APC

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/s/ Blake J. Lindemann
BLAKE J. LINDEMANN
Attorneys for Plaintiff
MICHELLE KELLY

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DATES IN THE COURT’S JANUARY
27, 2017 ORDER REQUIRING PARTIES TO MEET AND CONFER (Case No. 3:16-cv-06837)

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DATED: February 6, 2017

LAFAYETTE & KUMAGAI LLP

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/s/ Rebecca K. Kimura
REBECCA K. KIMURA
Attorney for Defendants
XEROX STATE AND LOCAL SOLUTIONS, INC.

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DATED: February 7, 2017

HANSON BRIDGETT LLP

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/s/ Samantha D. Wolff
SAMANTHA D. WOLFF
Attorney for Defendants GOLDEN GATE
BRIDGE, HIGHWAY AND TRANSPORTATION
DISTRICT AND BAY AREA TOLL AUTHORITY

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SIGNATURE ATTESTATION

for Plaintiff, and Samantha Wolff, counsel for Defendants Golden Gate Bridge, Highway

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and Transportation District and Bay Area Toll Authority, for the filing of this

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stipulation.

FAX

[phone]
[phone]

600
94105

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SAN FRANCISCO, CALIFORNIA

ATTORNEYS AT LAW

MISSION STREET, SUITE

I hereby attest that I have obtained the concurrence of Blake Lindemann, counsel

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LAFAYETTE & KUMAGAI LLP

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/s/ Rebecca K. Kimura

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ORDER
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Good cause appearing therefor and pursuant to the parties’ stipulation, it is hereby
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ORDERED that the deadline to propose a special master for appointment and the deadline to file
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a joint supplemental letter reflecting the results of the Parties’ meet and confer efforts be
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extended for one week to February 15, 2017.
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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2/7
DATED: ______________, 2017

____________________________________
RICHARD SEEBORG
United States District Judge

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DATES IN THE COURT’S JANUARY
27, 2017 ORDER REQUIRING PARTIES TO MEET AND CONFER (Case No. 3:16-cv-06837)