Litvinova v. The City and County of San Francisco

Filing 90

STIPULATION AND ORDER RE 89 CASE SCHEDULING AND FILING OF CROSS MOTIONS FOR SUMMARY JUDGMENT AS MODIFIED BY THE COURT. Jury Selection/Trial set for 9/13/2022 at 09:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Pretrial Conference set for 8/31/2022 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Signed by Chief Judge Richard Seeborg on 12/17/2021. (cl, COURT STAFF) (Filed on 12/17/2021)

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LINDA M. ROSS (SBN 133874)
[e-mail]
GEOFFREY SPELLBERG (SBN 121079)
[e-mail]
SPENCER J. WILSON (SBN 266938)
[e-mail]
ANASTASIA BONDERCHUK (SBN 309091)
[e-mail]
RENNE PUBLIC LAW GROUP®
350 Sansome Street, Suite 300
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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TATYANA LITVINOVA, individually and on
behalf of all others similarly situated,

RENNE PUBLIC LAW GROUP®

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Case No. 3:18-CV-01494-RS
STIPULATION REGARDING CASE
SCHEDULING AND FILING OF CROSS
MOTIONS FOR SUMMARY JUDGMENT;
ORDER AS MODIFIED BY THE COURT

Plaintiff,

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v.

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CITY AND COUNTY OF
SAN FRANCISCO,

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Defendant.

Complaint Filed:
Trial Date:

March 8, 2018
TBD

Pursuant to this Court’s direction at the November 18, 2021 Case Management Conference,

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Defendant City and County of San Francisco (the “City”) and Plaintiffs Tatyana Litvinova, et al. hereby

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submit the below stipulation and proposed order regarding case scheduling and filing of cross-motions

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for summary judgment. The City and plaintiffs in the related case of Kristen Silloway, et al. v. City and

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County of San Francisco., N.D. Cal. Case No. 3:20-cv-07400-RS are concurrently filing an identical

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stipulation and proposed order in that case.

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The parties agree that all motions for summary judgment will be filed in accordance with a cross-

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motion briefing schedule, defined below, so Defendant may file a single motion seeking summary

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judgment in both cases. If Plaintiffs in this case and/or Silloway move for summary judgment, Defendant

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should be permitted to file a consolidated opposition to those motions. Any brief or memorandum of
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STIP RE SCHEDULING AND CROSS MOT’NS FOR SUMM. J.; [PROPOSED] ORDER

CASE NO. 3:18-CV-01494-RS

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points and authorities filed by the Litvinova plaintiffs in support, opposition, or reply to a motion shall be

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subject to the page limitations of this Court’s Local Rules (25 pages for motions and opposition briefs

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and 15 pages for reply briefs) unless the parties make a timely request in order to increase the page

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limitation. Defendant City shall have an increased page limitation due to the fact Defendant will be

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filing consolidated briefs addressing two cases. Defendant’s page limitations for summary judgment

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briefing shall be 40 pages for motions and opposition briefs and 25 pages for any reply brief, unless the

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parties make a timely request in order to increase the page limitation.

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Additionally, pursuant to the Court’s direction to extend all court deadlines by 90 days, the parties
submit the below case schedule for approval by the Court. The Court will not approve any further

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extensions of the non-expert discovery deadlines. Starting with the close of discovery, the case schedule

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will be as follows:

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RENNE PUBLIC LAW GROUP®

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Feb. 18, 2022

Close of non-expert discovery

Mar. 18, 2022

Deadline to designate expert witnesses, FRCP 26(a)(2)

Apr. 15, 2022

Deadline to designate supplemental and rebuttal experts, FRCP 26(a)(2)

May 6, 2022

Deadline to complete expert discovery, FRCP 26(b)(4)

May 26, 2022

Motions for summary judgment due

June 16, 2022

Summary judgment opposition briefs due

June 30, 2022

Summary judgment reply briefs due

July 14, 2022

Hearing on motions for summary judgment due

July 14, 2022

Deadline to hear all pretrial motions

Aug. 31, 2022

Final Pretrial Conference

Sep. 13, 2022

Trial

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The Parties respectfully request that the Court approve the Parties’ above stipulation regarding
case scheduling and filing of cross-motions for summary judgment.

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STIP RE SCHEDULING AND CROSS MOT’NS FOR SUMM. J.; [PROPOSED] ORDER

CASE NO. 3:18-CV-01494-RS

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Dated: December 17, 2021

RENNE PUBLIC LAW GROUP®

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By: /s/Spencer J. Wilson
Spencer J. Wilson

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Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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Dated: December 17, 2021

PROMETHEUS PARTNERS

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By: /s/Eduardo G. Roy
Eduardo G. Roy

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Attorneys for Plaintiffs
TATYANA LITVINOVA, et al.

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RENNE PUBLIC LAW GROUP®

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ORDER

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PURSUANT TO STIPULATION AND THIS COURT’S PRIOR DIRECTION, IT IS SO
ORDERED.

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Dated:

December 17, 2021

RICHARD SEEBORG
Chief United States District Judge

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STIP RE SCHEDULING AND CROSS MOT’NS FOR SUMM. J.; [PROPOSED] ORDER

CASE NO. 3:18-CV-01494-RS