STIPULATED ADMINISTRATIVE MOTION FOR LEAVE TO EXCEED PAGE LIMIT FOR ATTACHMENTS RELATED TO DISCOVERY LETTER BRIEFS; AND [PROPOSED] ORDER

KANDIS A. WESTMORE, Magistrate Judge.

Pursuant to Northern District of California Civil Local Rules 7-11 and 7-12, Plaintiffs Monita Sharma and Eric Anderson ("Plaintiffs") and Defendant BMW of North America, LLC ("BMW NA" or "Defendant"), by and through their respective attorneys, hereby stipulate as follows:

STIPULATION

WHEREAS, the parties previously filed three joint discovery letter briefs (Dkt. Nos. 110, 111 and 113), which were terminated after the parties "failed to propose a compromise in their filings, . . . ." (Order Terminating Discovery Letter Briefs (Dkt. No. 114));

WHEREAS, the parties have extensively met and conferred and exchanged final proposed compromises pursuant to this Court's Order Terminating Discovery Letter Briefs, but were unable to reach agreements, including on discovery disputes regarding: (1) BMW NA's further responses and production of documents related to the design, manufacturing and testing for putative class vehicles; and (2) the limited scope of BMW NA's discovery responses;

WHEREAS, the parties have included proposed compromises in the respective sections of their discovery letter briefs pursuant to this Court's Order Terminating Discovery Letter Briefs;

WHEREAS, as with the parties' initial filings, two of the impending joint discovery letter briefs involve disputes that relate to several interrogatories and requests for production of documents and, for purposes of economy and judicial efficiency, the parties have structured their letter briefs so that they separately address a single overarching issue as opposed to filing multiple joint discovery letter briefs based on the same issue. For example, the parties' discovery dispute regarding "design and manufacturing" documents and responses encompasses twenty-two separate document requests and eleven interrogatory responses, and the parties' "discovery scope" dispute encompasses twenty separate document requests and eleven interrogatory responses;1

WHEREAS, the Standing Order for Magistrate Judge Westmore was revised on December 22, 2015, after the parties filed their initial joint discovery letter briefs, and now requires that "[a]ny attachments shall not exceed 12 pages." (Standing Order for Magistrate Judge Westmore ¶ 13); and

WHEREAS, the parties were able to present these overarching disputes in joint letters that do not exceed five pages (as required by the Court's Standing Order), because the parties are required to attach the propounded discovery and applicable responses as exhibits to the joint discovery letters (id.) and two of their joint letters relate to a single issue that involves several discovery requests, they are unable to fully comply with the page limitation for attachments. (See, e.g., Dkt. Nos. 111-1, 111-2, 111-4);

NOW, THEREFORE, undersigned counsel for the parties, having met and conferred and good cause appearing, hereby stipulate and agree to extend the page limit for attachments to two of their joint discovery letter briefs as follows:

IT IS HEREBY STIPULATED.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.