JOINT STATEMENT OF THE CASE

MORRISON C. ENGLAND, JR., District Judge.

Plaintiffs Laurie Nadeau; Robyn Coffin; and Dagny Magelssen ("Plaintiffs") and Defendants WealthCounsel, LLC and Insperity, Inc. ("Defendants," together with Plaintiffs referred to as the "Parties") hereby submit this Joint Statement of the Case.

1. The parties were unable to resolve the matter at the mediation.

2. The stay should be lifted as of November 15, 2017.

3. As provided in the Order filed September 13, 2017 (ECF No. 20), the case shall be deemed opened for purposes of this Court's Initial Scheduling Order (ECF No. 3) as of November 15, 2017.

4. Plaintiffs will file their Opposition to Defendants Motion to Transfer (ECF No. 21) by December 1, 2017.

5. Plaintiffs will file their First Amended Complaint to include federal claims under Title VII.

6. Defendants will file their Answer to Plaintiffs' First Amended Complaint within fifteen (15) days after service of the First Amended Complaint.

7. The Parties have conferred regarding discovery matters pursuant to Federal Rule of Civil Procedure 26(f) and agreed as follows:

a. The Parties will be deemed to have conferred with respect to discovery on November 15, 2017;

b. The discovery plan is as follows:

i. The Parties will exchange their initial disclosures pursuant to Rule 26(a) on December 11, 2017;

ii. Discovery will be needed on all the issues of liability and damages and should not be limited or phased;

iii. Electronically stored documents will be produced in PDF format, if practical, and other documents will be produced in a convenient format;

iv. The Parties do not anticipate issues about claims of privilege or protection of trial preparation materials, and any such issues that arise will be addressed on an ad hoc basis;

v. Because there are three Plaintiffs and two Defendants, the limitations on discovery will be doubled, except that depositions will be limited to 10 hours on the record spread over two days unless extended pursuant to the Parties agreement or Court order;

vi. Depositions will not be noticed until after January 8, 2018, so that the parties will, in the interim, concentrate on written discovery. Any deposition of Karl Clegg or Brett Pinegar will take place in Salt Lake City. Any depositions of the plaintiffs will take place in Sacramento. Any deposition of Tamira Ryan will take place in Sacramento, and Defendants will produce her so long as she is employed. Any depositions of the owners will take place in the cities in which they practice.

7. Aside from documents filed through the Court's electronic service, the Parties agree to electronic service of documents, including, among other things, documents produced during discovery. For purposes of calculating respective deadlines, documents initially served electronically will be treated as if they were served by mail adding three additional days, and responses thereto electronically served will be treated as if they were served by personal service. Electronic service will include service to the following individuals and addresses:

ORDER

IT IS SO ORDERED.