Giroux v. Essex Property Trust, Inc.

Filing 56

ORDER by Judge Haywood S. Gilliam, Jr. Granting In Part 55 Stipulation Re Case Schedule: Designation of Experts due by 11/15/2017; Designation of Rebuttal Experts due by 12/15/2017; Motions due by 2/15/2018; Responses due by 3/15/2018; Replies due by 3/29/2018; Motion Hearing set for 4/12/2018 02:00 PM before Hon. Haywood S. Gilliam Jr. (ndrS, COURT STAFF) (Filed on 8/15/2017)

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Joseph E. Addiego III (CA SBN 169522)
John D. Freed (CA SBN 261518)
DAVIS WRIGHT TREMAINE LLP
505 Montgomery Street, Suite 800
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
Attorneys for Defendant
ESSEX PROPERTY TRUST, INC.

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IN THE UNITED STATES DISTRICT COURT
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THE NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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ANGELE GIROUX,

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Plaintiff,
v.
ESSEX PROPERTY TRUST, INC.,
Defendant.

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STIPULATION RE CASE SCHEDULE

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Case No. 16-cv-01722-HSG
STIPULATION AND ORDER RE CASE
SCHEDULE IN RESPONSE TO DOCKET
NO. 54

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On August 3, 2017, the Court issued an Order (Dkt. No. 54) “DIRECTING the parties to

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meet and confer regarding a proposed case schedule and e-file a stipulation and proposed order

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with that case schedule” by August 11, 2017;

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In response to that Order, the parties HEREBY STIPULATE AND AGREE to the
following proposed case schedule, subject to the Court’s approval:

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Event

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Deadline to disclose Class Experts and Reports

November 15, 2017

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Deadline to disclose Class Rebuttal Experts and
Reports

December 15, 2017

Deadline to file and serve Class Certification
Motion/Motion to Strike Class Allegations

February 15, 2018

Deadline to file and serve Opposition to
Certification Motion/Motion to Strike Class
Allegations

April 19, 2018

Deadline to file and serve Reply to Certification
Motion/Motion to Strike Class Allegations

May 3, 2018

Hearing on Class Certification Motion/Motion
to Strike Class Allegations

May 24, 2018, 2:00 p.m.

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Deadline

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The parties propose the Court set the remaining deadlines after class certification has been
decided. Should the court prefer to schedule the remaining deadlines at this time, the parties
propose the following schedule:
Event

Deadline

Expert Disclosure and Exchange of Opening
Expert Reports

June 29, 2018

Exchange of Rebuttal Expert Reports

July 20, 2018

Close of Fact Discovery

August 31, 2018

Deadline to File Dispositive Motions

September 20, 2018

Last Day to Hear Dispositive Motions

October 25, 2018

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STIPULATION RE CASE SCHEDULE

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IT IS SO STIPULATED.

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DATED: August 15, 2017
DAVIS WRIGHT TREMAINE LLP
Joseph E. Addiego III
John D. Freed

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By: /s/ Joseph E. Addiego III
Joseph E. Addiego III

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Attorneys for Defendant
ESSEX PROPERTY TRUST, INC.

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HKM EMPLOYMENT ATTORNEYS LLP
Donald W. Heyrich

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By: /s/ Donald W. Heyrich
Donald W. Heyrich

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Attorneys for Plaintiff

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STIPULATION RE CASE SCHEDULE

CERTIFICATION OF CONCURRENCE

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Pursuant to L.R. 5-1, I hereby attest that Donald W. Heyrich, counsel for Plaintiff Angele

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Giroux, has provided his concurrence in the electronic filing of the foregoing document entitled

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STIPULATION [AND PROPOSED ORDER] RE CASE SCHEDULE IN RESPONSE TO

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DOCKET NO. 54.

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/s/ Joseph E. Addiego III
Joseph Addiego III

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STIPULATION RE CASE SCHEDULE

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ORDER

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Presently before the Court is the parties’ Stipulation [and Proposed Order] Re Case

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Schedule in Response to Docket No. 54. Good cause appearing, the Court GRANTS IN PART

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the Stipulation as follows:

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1. The parties’ stipulated schedule and case deadlines stated above are adopted through

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the class certification motion hearing and shall be the case schedule for this matter

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except: February 15, 2018-last day to file class certification motion; March 15, 2018-

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last day to file opposition; March 29, 2018-last day to file reply; and April 12, 2018 at

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2:00 p.m.-last day to hear motion for class certification.
2. These dates may only be altered by order of the Court and only upon a showing of good

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cause. The parties are directed to review and comply with this Court’s Civil Pretrial and
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Trial Standing Orders.
IT IS SO ORDERED.
Date: August 15, 2017

________________________________
Hon. Haywood S. Gilliam, Jr.
United States District Judge

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STIPULATION RE CASE SCHEDULE