Woods v. Google, Inc.

Filing 219

ORDER REGARDING EXPERT DISCOVERY re 218 Stipulation filed by Google, Inc. Signed by Judge Edward J. Davila on 6/8/2015. (ecg, COURT STAFF) (Filed on 6/8/2015)

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KESSLER TOPAZ
MELTZER & CHECK, LLP
Stacey M. Kaplan (Bar No. 241989)
One Sansome Street, Suite 1850
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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-andSean M. Handler (Pro Hac Vice)
Matthew L. Mustokoff (Pro Hac Vice)
Ryan T. Degnan (Pro Hac Vice)
Margaret E. Onasch (Pro Hac Vice)
Daniel C. Mulveny (Pro Hac Vice)
280 King of Prussia Road
Radnor, PA 19087
Telephone: [phone]
Facsimile: [phone]

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Interim Co-Class Counsel

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MAYER BROWN LLP
Edward D. Johnson (SBN 189475)
[e-mail]
Donald M. Falk (SBN150256)
[e-mail]
Eric B. Evans (SBN 232476)
[e-mail]
Dominique-Chantale Alepin (SBN 241648)
[e-mail]
Two Palo Alto Square, Suite 300
3000 El Camino Real
Palo Alto, CA 94306-2112
Telephone: [phone]

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NIX, PATTERSON & ROACH, LLP
Jeffrey J. Angelovich (Pro Hac Vice)
Brad E. Seidel (Pro Hac Vice)
Andrew G. Pate (Pro Hac Vice)
Chad E. Ihrig (Pro Hac Vice)
3600 N. Capital of Texas Highway
Building B, Suite 350
Austin, TX 78746
Telephone: [phone]
Facsimile: [phone]

Attorneys for Defendant Google Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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RICK WOODS, Individually and on Behalf of
All Others Similarly Situated,

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Plaintiff,
vs.

Case No. 11-cv-1263-EJD
JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING
EXPERT DISCOVERY

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GOOGLE INC.,
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Defendant.
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JOINT STIPULATION AND [PROPOSED] ORDER
REGARDING EXPERT DISCOVERY, CASE NO 11-CV-1263

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Plaintiff Rick Woods and Defendant Google Inc., by and through their counsel of record

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herein, hereby stipulate and agree, subject to Court approval, to the following regarding the scope

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of discovery and testimony relating to experts in this matter:

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WHEREAS, in order to avoid consuming the parties’ and the Court’s time and resources

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on potential discovery issues relating to experts, the parties have agreed to certain limitations on

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the scope of expert-related discovery and testimony in this matter.

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IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff and Defendant
and subject to Court approval, as follows:
The following categories of data, information, or documents need not be disclosed by any
party, and are outside the scope of permissible discovery (including deposition questions):
1.

Any notes or other writings taken or prepared by or for an expert witness in

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connection with this matter, including correspondence or memos to or from, and notes of

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conversations with any person, including, but not limited to, the expert’s assistants and/or clerical

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or support staff, other fact or expert witnesses or non-testifying expert consultants, or attorneys

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for the party offering the testimony of such expert witness, unless the expert witness relies on

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those notes or other writings in connection with the expert witness’ opinions in this matter; and

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2.

Any oral or written communication between an expert witness and any person,

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including, but not limited to, the expert’s assistants and/or clerical or support staff, other fact or

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expert witnesses or non-testifying expert consultants, or attorneys for the party offering the

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testimony of such expert witness, unless the expert witness relies on those oral or written

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communications in connection with the expert witness’ opinions in this matter.

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-1JOINT STIPULATION AND [PROPOSED] ORDER
REGARDING EXPERT DISCOVERY, CASE NO. 11-CV-1263

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IT IS SO STIPULATED

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DATED: June 4, 2015

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KESSLER TOPAZ MELTZER & CHECK, LLP
By:

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/s Matthew Mustakoff
Matthew L. Mustokoff

NIX, PATTERSON & ROACH, LLP
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By:
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/s Brad Seidel
Brad E. Seidel

Interim Co-Lead Class Counsel

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DATED: June 4, 2015

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MAYER BROWN LLP
By:

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/s Edward D. Johnson
Edward D. Johnson

Counsel for Defendant, Google Inc.
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Filer’s Attestation: In compliance with General Order 45(X)(B), I hereby attest that concurrence
in the filing of this Stipulation has been obtained from Interim Co-Lead Class Counsel, Matthew
Mustakoff and Brad Seidel.

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/s/ Edward D. Johnson
Edward D. Johnson

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.

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IT IS SO ORDERED
6/8/2015
DATED: ____________

Honorable Edward J. Davila

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-2JOINT STIPULATION AND [PROPOSED] ORDER
REGARDING EXPERT DISCOVERY, CASE NO. 11-CV-1263