Kelly v. Bay Area Toll Authority et al

Filing 36

STIPULATION AND ORDER RE 34 TO FURTHER CONTINUE DATES IN THE COURT'S JANUARY 27 ORDER REQUIRING PARTIES TO MEET AND CONFER. Signed by Judge Richard Seeborg on 2/16/17. (cl, COURT STAFF) (Filed on 2/16/2017)

1
2
3
4
5
6
7

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.

8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10

Plaintiff,

FAX

[phone]
[phone]

600
94105

13

SAN FRANCISCO, CALIFORNIA

MISSION STREET, SUITE

ATTORNEYS AT LAW

12

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

101

LAFAYETTE & KUMAGAI LLP

11

14

v.

15

17

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

18

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

Defendants.

16

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

19
20
21

STIPULATION AND REQUEST

22

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

23

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

24

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

25

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

26

counsel hereby stipulate as follows:

27
28

WHEREAS, on January 18, 2017, Xerox filed a letter with the Court requesting guidance
on a discovery dispute with Plaintiff;
STIPULATION AND [PROPOSED] ORDER TO FURTHER CONTINUE DATES IN THE COURT’S
JANUARY 27, 2017 ORDER REQUIRING PARTIES TO MEET AND CONFER
(Case No. 3:16-cv-06837)

1

1

WHEREAS, on January 20, 2017, Plaintiff filed a letter with the Court in response;

2

WHEREAS, on January 27, 2017, the Court issued an Order Requiring Parties to Meet

3
4
5
6

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, on February 7, 2017, the Parties filed a Stipulation and Proposed Order

7

requesting to continue the deadline to file a joint supplemental letter to February 15, 2017;

8

WHERAS, on February 7, 2017, the Court granted the Parties request to extend the

9

14, 2017 and February 15, 2017, over the items in Xerox’s and Plaintiff’s discovery letters;

13

FAX

[phone]
[phone]

12

SAN FRANCISCO, CALIFORNIA

ATTORNEYS AT LAW

30, 2017, February 2, 2017, February 6, 2017 and February 14, 2017, and by email on February

101

LAFAYETTE & KUMAGAI LLP

11
600
94105

WHEREAS, pursuant to the Order, the Parties met and conferred by telephone on January

MISSION STREET, SUITE

10

deadline to February 15, 2017;

14
15

WHEREAS, the Parties are continuing to meet and confer to discuss the items in their
discovery letters;
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties through

16

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

17

the results of the Parties’ meet and confer efforts be extended for two days to February17, 2017.

18
19

DATED: February 15, 2017

LINDEMANN LAW FIRM, APC

20
/s/ Blake J. Lindemann

21

BLAKE J. LINDEMANN
Attorneys for Plaintiff
MICHELLE KELLY

22
23
24
25
26
27
28

DATED: February 15, 2017

LAFAYETTE & KUMAGAI LLP
/s/ Rebecca K. Kimura
REBECCA K. KIMURA
Attorney for Defendants
XEROX STATE AND LOCAL SOLUTIONS, INC.
2

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

1
2

DATED: February 15, 2017

HANSON BRIDGETT LLP

3

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

4
5
6
7
8
9

SIGNATURE ATTESTATION
I hereby attest that I have obtained the concurrence of Blake Lindemann, counsel
for Plaintiff, and Samantha Wolff, counsel for Defendants Golden Gate Bridge, Highway

FAX

[phone]
[phone]

13

SAN FRANCISCO, CALIFORNIA

ATTORNEYS AT LAW

/s/ Rebecca K. Kimura

12

101

600
94105

stipulation.

MISSION STREET, SUITE

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

11
LAFAYETTE & KUMAGAI LLP

10

14
ORDER
15
Good cause appearing therefor and pursuant to the parties’ stipulation, it is hereby
16
ORDERED that the deadline to propose a special master for appointment and the deadline to file
17
a joint supplemental letter reflecting the results of the Parties’ meet and confer efforts be
18
extended for two days to February 17, 2017.
19
PURSUANT TO STIPULATION, IT IS SO ORDERED.
20
21
22
23

DATED: ______________, 2017
2/16

____________________________________
RICHARD SEEBORG
United States District Judge

24
25
26
27
28

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