Filed: Nov. 18, 2014
Latest Update: Nov. 18, 2014
Summary: STIPULATED REQUEST AND ORDER MODIFYING CASE MANAGEMENT SCHEDULE CHARLES R. BREYER, District Judge. The undersigned counsel, on behalf of Plaintiffs Betty Dukes, Patricia Surgeson, Edith Arana, Deborah Gunter, and Christine Kwapnoski ("Plaintiffs") and Defendant Wal-Mart Stores, Inc. ("Wal-Mart," and collectively, with Plaintiffs, the "Parties"), hereby stipulate as follows: RECITALS WHEREAS the parties submitted a joint proposed order regarding case management on May 2, 2014, which was adop
Summary: STIPULATED REQUEST AND ORDER MODIFYING CASE MANAGEMENT SCHEDULE CHARLES R. BREYER, District Judge. The undersigned counsel, on behalf of Plaintiffs Betty Dukes, Patricia Surgeson, Edith Arana, Deborah Gunter, and Christine Kwapnoski ("Plaintiffs") and Defendant Wal-Mart Stores, Inc. ("Wal-Mart," and collectively, with Plaintiffs, the "Parties"), hereby stipulate as follows: RECITALS WHEREAS the parties submitted a joint proposed order regarding case management on May 2, 2014, which was adopt..
More
STIPULATED REQUEST AND ORDER MODIFYING CASE MANAGEMENT SCHEDULE
CHARLES R. BREYER, District Judge.
The undersigned counsel, on behalf of Plaintiffs Betty Dukes, Patricia Surgeson, Edith Arana, Deborah Gunter, and Christine Kwapnoski ("Plaintiffs") and Defendant Wal-Mart Stores, Inc. ("Wal-Mart," and collectively, with Plaintiffs, the "Parties"), hereby stipulate as follows:
RECITALS
WHEREAS the parties submitted a joint proposed order regarding case management on May 2, 2014, which was adopted by the Court on May 6, 2014 (Dkt. No. 1003);
WHEREAS the parties have propounded substantial supplemental and new discovery since that Order was entered and resolved many differences regarding written discovery requests by extensive conferences between the parties;
WHEREAS the parties are in the midst of the depositions of the five plaintiffs and have agreed to schedule the depositions of Wal-Mart's witnesses to avoid conflicting with the busy retail holiday season, as needed;
WHEREAS despite the best efforts of both parties to comply with the existing case management schedule, the parties will not be able to complete the discovery each has served by November 21, 2014 as scheduled; and
WHEREAS in light of both parties' diligence since the entry of the Court's May 6 order, the parties do not anticipate the need for substantial new written discovery. The new deadlines will allow for an orderly completion of the written discovery both sides have already served, and, if necessary, for follow-up discovery the parties could not have previously anticipated despite reasonable efforts to complete discovery by the current deadline; and
WHEREAS no prior requests for extension have been made with respect to the merits discovery period.
STIPULATION
Accordingly, the parties now jointly stipulate and respectfully request that this Court order the following changes to the existing schedule:
Event Current Date Proposed New Date
Date certain for Wal-Mart to provide requested 2014 December 12, 2015
data to plaintiffs
Non-Expert Discovery Cutoff / Expert November 21, 2014 February 16, 2015
Disclosures
Responsive Expert Disclosures December 22, 2014 March 16, 2016
Dispositive Motion Deadline January 9, 2015 April 3, 2015
Briefs in Opposition February 6, 2015 May 1, 2015
Briefs in Reply February 20, 2015 May 15, 2015
Proposed hearing date March 6, 2015 June 5, 2015
Joint Proposed Pretrial Order May 18, 2015 August 21, 2015
Pretrial Conference May 26, 2015 August 28, 2015
Trials June 1, 2015 September 8, 2015
Pursuant to Local Rule 6-2(a), the declaration of Christine E. Webber in support of this stipulation is filed herewith.
IT IS SO STIPULATED.
ORDER
Pursuant to the above stipulation, the Stipulation and Order regarding the case management schedule is approved.
