Wood v. IGATE Technologies, Inc.

Filing 58

ORDER GRANTING 57 Second STIPULATION to Extend Case Deadlines. Discovery due by 3/31/2016. Signed by Judge Jeffrey S. White on 2/22/16. (jjoS, COURT STAFF) (Filed on 2/22/2016)

Case 4:15-cv-00799-JSW Document 57 Filed 02/19/16 Page 1 of 4

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MELINDA S. RIECHERT, BAR NO. 65504
SACHA M. STEENHOEK, BAR NO. 253743
MORGAN, LEWIS & BOCKIUS LLP
One Market, Spear Street Tower
San Francisco, CA 94105-1126
Tel: [phone]
Fax: [phone]
e-mail: [e-mail]
e-mail: [e-mail]
Attorneys for Defendant
IGATE TECHNOLOGIES, INC.
JOSEPH CLAPP, Bar No. 99194
AIMAN-SMITH & MARCY
7767 Oakport Street, Suite 1150
Oakland, CA 94621
Tel:
510.590.7115

Fax: [phone]
e-mail: [e-mail]
Attorneys for Plaintiff
BARBARA WOOD

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
BARBARA WOOD,

Case No. 3:15-cv-00799-JSW

Plaintiff,

STIPULATION AND [PROPOSED] ORDER
TO EXTEND CASE DEADLINES

v.
IGATE TECHNOLOGIES, INC., a business entity,
form unknown; and Does 1 through 25, inclusive,
Defendant.

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TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
WHEREAS, pursuant to the Court’s August 17, 2015 Order (Docket No. 48), the Court
set deadlines for the close of expert and non-expert discovery, dispositive motions, and trial;

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WHEREAS, the parties have been engaged in discovery, but because of confidentiality

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agreements with third parties and for reasons beyond Defendant’s control, Defendant has only

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very recently been able to produce to Plaintiff key documents and information critical to this case;

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION TO CONTINUE
COURT DEADLINES
Case No. 3:15-CV-00799-JSW

Case 4:15-cv-00799-JSW Document 57 Filed 02/19/16 Page 2 of 4

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WHEREAS, since the parties began discovery, the Defense has worked diligently to

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secure permission to produce such key documents and information, and obtained permission to

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produce it on Monday, February 8;

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WHEREAS, the parties have not been able to conduct meaningful depositions without
access to these key documents and information;

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WHEREAS, now that Defendant has been able to produce the key documents and

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information, the parties have scheduled necessary depositions for the last week of February and

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first two weeks of March, 2016;

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WHEREAS, the parties believe that an extension of the current case deadlines are
necessary to conduct meaningful discovery on one of the most critical issues in this matter.
THEREFORE, for good cause showing, the parties request that the Court amend the
previously-scheduled deadlines as follows:

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Close of Non-expert Discovery: March 31, 2016

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED: February 19, 2016

/s/ Joseph Clapp
Attorneys for Plaintiff

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DATED: February 19, 2015

/s/ Sacha Steenhoek
Attorneys for Defendant

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION TO CONTINUE
COURT DEADLINES
Case No. 3:15-CV-00799-JSW

Case 4:15-cv-00799-JSW Document 57 Filed 02/19/16 Page 4 of 4

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PURSUANT TO STIPULATION, and having shown good cause, the case deadlines are

extended as follows:
Close of Non-expert Discovery: March 31, 2016

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IT IS SO ORDERED.

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February 22, 2016
DATED: ________________________

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_____________________________________
HON. JEFFREY S. WHITE
UNITED STATES DISTRICT JUDGE

DB2/ 28135988

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION TO CONTINUE
COURT DEADLINES
Case No. 3:15-CV-00799-JSW