Pravin et al v. Wipro, Inc.

Filing 55

STIPULATION AND ORDER TO MODIFY CASE SCHEDULE. Further Case Management Conference set for 3/31/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Jury Selection set for 6/6/2011 09:00 AM in Courtroom 3, 17th Floor, San Francisco before Hon. Ri chard Seeborg. Jury Trial set for 6/6/2011 09:00 AM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Pretrial Conference set for 5/26/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 3/3/11. (cl, COURT STAFF) (Filed on 3/4/2011)

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Pravin Jain et al v. Wipro, Inc. Doc. 55 *E-Filed 3/4/11* 1 2 3 4 5 6 7 8 9 10 Ropers Majeski Kohn & Bentley 11 A Professional Corporation San Jose MICHAEL J. IOANNOU (SBN 95208) LITA M. VERRIER (181183) DANIEL P. McKINNON (SBN 234749) ROPERS, MAJESKI, KOHN & BENTLEY 50 West San Fernando Street, Suite 1400 San Jose, CA 95113-2429 Telephone: (408) 287-6262 Facsimile: (408) 918-4501 mioannou@rmkb.com lverrier@rmkb.com dmckinnon@rmkb.com Attorneys for Defendant WIPRO, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PRAVIN JAIN, RANDY HOLTHAUS, DILIP KUKREJA, MARK WARNER and DOUGLAS TANNER, Plaintiffs, v. WIPRO, INC., a Delaware corporation, Defendant. CASE NO. 5:09-cv-02743 RS STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE Judge: The Honorable Richard Seeborg RC1/5903295.1/NB -1- STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE 5:09-CV-02743 RS Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 Ropers Majeski Kohn & Bentley 11 A Professional Corporation San Jose Plaintiffs Pravin Jain, Randy Holthaus, Dilip Kukreja, Mark Warner, and Douglas Tanner (collectively "Plaintiffs") and Defendant Wipro, Inc. ("Wipro") agree as follows: The parties have been working diligently to complete discovery before the current February 28, 2011 deadline for non-expert discovery set forth in the modified Case Management Scheduling Order entered on December 14, 2010 ("Scheduling Order") (Docket No. 51). This discovery included depositions of key witnesses located in India. During the first two weeks of February, 2011, the parties traveled to and conducted nine depositions in India, including Wipro's corporate representatives, a plaintiff, and non-party witnesses who live in India. During these depositions, the parties discovered additional discovery that needed to be completed, including the exchange of additional electronically stored information ("ESI") maintained in India on back-up drives or tapes by Plaintiffs and Defendant, and depositions of additional witnesses. The parties are retrieving this ESI and processing it for production. The exchange of this additional ESI will complete the parties' production of the large volume of ESI that has already been exchanged through the parties' initial disclosures and written discovery. The parties have also been working to schedule the depositions of the additional witnesses. The parties have also not received the transcripts for the witnesses whose depositions were completed in India. These deposition transcripts are of key witnesses, and will be used in moving and/or opposing the parties' respective motions for summary judgment/adjudication. Under the current Scheduling Order, the parties would not have the transcripts to use in support of their respective motions, since dispositive motions would be filed on March 3, 2011. To allow the parties to produce the additional ESI, accommodate the witnesses' schedules, obtain the transcripts of the witnesses whose depositions were taken in India, and leave sufficient time for trial preparation, the parties agreed to a short continuance of all pre-trial and trial dates. The parties further agree this will be the final modification of the scheduling order. Consequently, IT IS HEREBY STIPULATED between Plaintiffs and Wipro, through their respective counsel of record, and pursuant to Civil Local Rule 6-2, that, to the extent allowed by the Court's calendar, the dates set forth in the Scheduling Order be modified as follows: RC1/5903295.1/NB 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -1- STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE 5:09-CV-02743 RS 1 2 3 4 5 6 7 8 9 10 Ropers Majeski Kohn & Bentley 11 A Professional Corporation San Jose Close of Non-Expert Discovery Plaintiffs' Expert Disclosures Defendant's Expert Disclosures Further Case Management Conference Close of Expert Discovery Meet and Confer re Pretrial Conference Dispositive Motions Heard No Later Than Submit Pretrial Statements Final Pre-Trial Conference Jury Trial Begins IT IS SO STIPULATED. Dated: March 3, 2011 March 28, 2011 April 7, 2011 April 18, 2011 April 21, 2011 @ 10:00 a.m. March 31, 2011 @ 10:00 a.m. May 4, 2011 May 9, 2011 May 5, 2011 May 18, 2011 May 26, 2011 @ 10:00 a.m. June 6, 2011 April 7, 2011 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SUSMAN GODFREY LLP By: /s/ Stephen E. Morrissey STEPHEN E. MORRISSEY Attorneys for Plaintiffs Pravin Jain, Randy Holthaus, Dilip Kukreja, Mark Warner and Douglas Tanner Dated: March 3, 2011 ROPERS, MAJESKI, KOHN & BENTLEY By: /s/ Michael J. Ioannou MICHAEL J. IOANNOU Attorneys for Defendant WIPRO, INC. I, Michael J. Ioannou, am the ECF user whose identification and password are being used to file this stipulation. In compliance with General Order 45.X.B, I hereby attest that the other signatory has concurred in this filing. Dated: March 3, 2011 ROPERS, MAJESKI, KOHN & BENTLEY By: /s/ Michael J. Ioannou MICHAEL J. IOANNOU Attorneys for Defendant WIPRO, INC. -2RC1/5903295.1/NB STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE 5:09-CV-02743 RS 1 2 3 4 5 6 7 8 9 10 Ropers Majeski Kohn & Bentley 11 A Professional Corporation San Jose [PROPOSED] ORDER Pursuant to stipulation, IT IS HEREBY ORDERED, that the dates set forth in the modified Case Management Scheduling Order, entered on December 14, 2010 ("Scheduling Order") (Docket No. 51) be modified as follows: Close of Non-Expert Discovery Plaintiffs' Expert Disclosures Defendant's Expert Disclosures Further Case Management Conference Close of Expert Discovery Meet and Confer re Pretrial Conference Dispositive Motions Heard No Later Than Submit Pretrial Statements Final Pre-Trial Conference Jury Trial Begins March 28, 2011 April 7, 2011 April 18, 2011 April 21, 2011 @ 10:00 a.m. May 4, 2011 May 9, 2011 May 5, 2011 May 18, 2011 May 26, 2011 @ 10:00 a.m. June 6, 2011 April 7, 2011 3/31/11 @ 10:00 a.m. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3/3 Dated: ______________, 2011 By:_______________________________________ The Honorable Richard Seeborg UNITED STATES DISTRICT JUDGE -3RC1/5903295.1/NB STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE SCHEDULE 5:09-CV-02743 RS

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