Elias v. Hewlett-Packard Company
Filing
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STIPULATION AND ORDER re 60 STIPULATION WITH PROPOSED ORDER re 59 Discovery Dispute Joint Report #2. Signed by Magistrate Judge Howard R. Lloyd on 5/16/2014. (hrllc1, COURT STAFF) (Filed on 5/16/2014)
*E-Filed: May 16, 2014*
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GUTRIDE SAFIER LLP
ADAM J. GUTRIDE (State Bar No. 181446)
SETH A. SAFIER (State Bar No. 197427)
TODD KENNEDY (State Bar No. 250267)
KRISTEN SIMPLICIO (State Bar No. 263291)
835 Douglass Street
San Francisco, California 94114
Telephone: (415) 336-6545
Facsimile: (415) 449-6469
Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNA
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DAVID ELIAS, an individual, on behalf of
himself, the general public and those similarly situated
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STIPULATION REGARDING
DISCOVERY DISPUTE JOINT
REPORT No. 2
AND [PROPOSED] ORDER
Plaintiff,
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CASE NO. 5:12-cv-00421
v.
HEWLETT-PACKARD COMPANY; AND DOES 1
THROUGH 50
Defendants
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WHEREAS, on May 7, 2014, Plaintiff and Defendant Hewlett Packard Company (“HP”)
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filed a Discovery Dispute Joint Report #2 (the “Joint Report”), concerning the scheduling of the
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parties’ respective depositions and the inspection of Plaintiff’s Pavilion s5305z desktop computer
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[Dkt. #59];
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WHEREAS, following the filing of the Joint Report, the parties continued to meet and
confer regarding the disputed matters set forth in the Joint Report;
WHEREAS, through these further meet-and-confer efforts, the parties have agreed to a
schedule for the completion of the outstanding depositions and computer inspection;
WHEREAS, the parties desire to resolve the matters set forth in the Joint Report by
setting forth a stipulated schedule to be approved by the Court;
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STIPULATION REGARDING DISCOVERY DISPUTE JOINT REPORT NO. 2 AND [PROPOSED] ORDER
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NOW, THEREFORE, IT IS STIPULATED, by and between the undersigned parties,
through their respective counsel of record, that the outstanding depositions and computer
inspection will proceed according to the following schedule, subject to the Court’s approval,
thereby fully resolving the issues set forth in the Joint Report:
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Event
Date
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Inspection of Plaintiff’s s5305z Desktop Computer
May 28, 2014
Deposition of Girish Srinivasan, HP’s Rule 30(b)(6) Designee
on Topics Pertaining to Sales and Marketing
June 6, 2014
Depositions of Plaintiff David Elias, and Plaintiff’s wife,
Kenia Elias
June 12, 2014
Deposition of Karl Hassur, HP’s Rule 30(b)(6) Designee on
Topics Pertaining to Technology
June 13, 20141
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Dated: May 15, 2014
/s/ Seth A. Safier
Seth A. Safier
GUTRIDE SAFIER LLP
835 Douglass Street
San Francisco, California 94114
Attorneys for Plaintiff, David Elias
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Dated: May 15, 2014
/s/ Timothy W. Loose
Timothy W. Loose
Gibson, Dunn & Crutcher LLP
333 South Grand Avenue, Los Angeles, CA 90071
Attorneys for Defendant, Hewlett-Packard Company
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Mr. Hassur currently is scheduled for jury duty from June 2–6. Should Mr. Hassur be selected
to serve on a trial that is continuing at the time of his currently scheduled deposition, the parties
agree to promptly find an alternative and mutually agreeable date for the deposition to occur.
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STIPULATION REGARDING DISCOVERY DISPUTE JOINT REPORT NO. 2 AND [PROPOSED] ORDER
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[PROPOSED] ORDER
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Pursuant to the stipulation of the parties, and GOOD CAUSE APPEARING
THEREFOR, the issues set forth in Discovery Dispute Joint Report No. 2 are resolved and the
outstanding discovery shall proceed according to the following schedule:
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Event
Date
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Inspection of Plaintiff’s s5305z Desktop Computer
May 28, 2014
Deposition of Girish Srinivasan, HP’s Rule 30(b)(6) Designee
on Topics Pertaining to Sales and Marketing
June 6, 2014
Depositions of Plaintiff David Elias, and Plaintiff’s wife,
Kenia Elias
June 12, 2014
Deposition of Karl Hassur, HP’s Rule 30(b)(6) Designee on
Topics Pertaining to Technology
June 13, 20142
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IT IS SO ORDERED.
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DATED: May 16, 2014
THE HONORABLE HOWARD R. LLOYD
UNITED STATES MAGISTRATE JUDGE
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Mr. Hassur currently is scheduled for jury duty from June 2–6. Should Mr. Hassur be selected
to serve on a trial that is continuing at the time of his currently scheduled deposition, the parties
agree to promptly find an alternative and mutually agreeable date for the deposition to occur.
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STIPULATION REGARDING DISCOVERY DISPUTE JOINT REPORT NO. 2 AND [PROPOSED] ORDER
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