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CRANE CO. v. THE GOODYEAR TIRE & RUBBER COMPANY, 2:14-CV-06509-DMG-AGR. (2014)

Court: District Court, C.D. California Number: infdco20150123g16 Visitors: 11
Filed: Dec. 18, 2014
Latest Update: Dec. 18, 2014
Summary: ORDER GRANTING JOINT STIPULATION RE CERTAIN DISCOVERY ISSUES JOINT STIPULATION RE CERTAIN DISCOVERY ISSUES ALCIA G. ROSENBERG, Magistrate Judge. Pursuant to stipulation of the parties, IT IS SO ORDERED that the Stipulation re Certain Discovery Issues is granted in the above entitled action. IT IS SO GRANTED. STIPULATION COME NOW, CRANE CO., Plaintiff in above captioned matter, and THE GOODYEAR TIRE & RUBBER COMPANY, and submit this STIPULATION regarding discovery in the above referenced
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ORDER GRANTING JOINT STIPULATION RE CERTAIN DISCOVERY ISSUES

JOINT STIPULATION RE CERTAIN DISCOVERY ISSUES

ALCIA G. ROSENBERG, Magistrate Judge.

Pursuant to stipulation of the parties, IT IS SO ORDERED that the Stipulation re Certain Discovery Issues is granted in the above entitled action.

IT IS SO GRANTED.

STIPULATION

COME NOW, CRANE CO., Plaintiff in above captioned matter, and THE GOODYEAR TIRE & RUBBER COMPANY, and submit this STIPULATION regarding discovery in the above referenced matter, and show the Court as follows:

1.) Plaintiff in this case seeks damages under theories of contractual and comparative equitable indemnity. It is one of four cases currently pending in which Plaintiff makes such claims against Defendant. This Stipulation is entered into in an effort to streamline the discovery process, to avoid unnecessary duplication of effort by the Parties and the Courts before whom the indemnity claims are pending, and to avoid inconsistent rulings on discovery issues. 2.) The Parties stipulate and agree that discovery conducted in any case in which CRANE CO. has or does assert contractual or comparative equitable indemnity claims against THE GOODYEAR TIRE & RUBBER COMPANY, whether by direct, cross-claim or third-party complaint, shall be treated as if taken in any other case in which CRANE CO. has asserted a claim for contractual or comparative equitable indemnity against THE GOODYEAR TIRE & RUBBER COMPANY, as of the date of this Stipulation or that may be filed thereafter.. Each party specifically reserves their rights with respect to admissibility, relevance and all other evidentiary objections that are asserted in the responses to discovery or as otherwise permitted. 3.) The Parties further stipulate and agree that they shall: a) On or before November 14, 2014 exchange in electronic format all documents which had previously been produced by THE GOODYEAR TIRE & RUBBER COMPANY to CRANE CO., and by CRANE CO. to THE GOODYEAR TIRE & RUBBER COMPANY, from July 24, 2013 to May 3, 2014; b) The documents produced on or before November 14, 2014 shall be accepted by the Parties as responsive, in part, to Requests for Production of Documents which were served by CRANE CO. on THE GOODYEAR TIRE & RUBBER COMPANY in the matter of Hill v. Certainteed Corp., et. al., LOASD Case No. BC544287 and the Demand for Production of Documents served by CRANE CO. on THE GOODYEAR TIRE & RUBBER COMPANY on October 22, 2014 in the instant action. The Parties specifically reserve their rights to seek additional documents which a Party believes should be produced in response to Requests to Produce. c) The Parties further stipulate and agree that production of the documents referenced in Paragraph 3(a) is in no way to be construed as a waiver of the right to object to any Request for Production of Documents and each Party specifically retains the right to submit written objections to the Requests for Production of Documents within the time permitted under the Federal Rules of Civil of Civil Procedure, as applicable. d) The Parties specifically agree that the production of documents discussed in Paragraph 3 shall not eliminate the requirement to serve a written response to any discovery, nor shall it waive any Party's right to seek to compel further response. 4.) The Parties specifically stipulate and agree that, to expedite production, documents submitted by THE GOODYEAR TIRE & RUBBER COMPANY on November 14 may contain designations noting the documents as "CONFIDENTIAL" or similar language. The Parties stipulate and agree that on or before December 5, 2014 THE GOODYEAR TIRE & RUBBER COMPANY shall provide CRANE CO. with a clean copy of these documents, noting as confidential only those which THE GOODYEAR TIRE & RUBBER COMPANY seeks to maintain as confidential. Any documents for which THE GOODYEAR TIRE & RUBBER COMPANY seeks to maintain the confidential designation shall be used only for the purposes of CRANE CO.'s prosecution of its claims against GOODYEAR and GOODYEAR's defense of those claims, as further specified in a stipulated protective order to be presented to the court, or if no stipulation is reached, pursuant to a protective order entered by the Court. 5.) The Parties agree that in the course of this litigation certain documents may be requested and produced in discovery which the propounding Party seeks to designate as confidential. The Parties expect to submit to the Court on or before December 5, 2014, a Stipulated Protective Order that shall set forth the manner in which confidential documents shall be treated. If the Parties have not been able to agree on a Stipulated Protective Order prior to December 5, 2014, then any Party desiring a protective order shall file a motion with the Court.

SO STIPULATED.

IT IS SO ORDERED.

Source:  Leagle

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