Filed: Sep. 07, 2012
Latest Update: Sep. 07, 2012
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE JOINT LETTER REGARDING DISCOVERY DISPUTES DONNA M. RYU, Magistrate Judge. The parties hereby stipulate as follows: WHEREAS, on or about April 17, 2012, Plaintiffs filed letters with the Court regarding Plaintiffs' issues with Defendant Specialty's Caf and Bakery, Inc. and Defendant Craig Saxton's discovery responses. On April 20, 2012, the Court entered an Order requiring the parties to meet and confer regarding the discovery dispu
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE JOINT LETTER REGARDING DISCOVERY DISPUTES DONNA M. RYU, Magistrate Judge. The parties hereby stipulate as follows: WHEREAS, on or about April 17, 2012, Plaintiffs filed letters with the Court regarding Plaintiffs' issues with Defendant Specialty's Caf and Bakery, Inc. and Defendant Craig Saxton's discovery responses. On April 20, 2012, the Court entered an Order requiring the parties to meet and confer regarding the discovery disput..
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STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE JOINT LETTER REGARDING DISCOVERY DISPUTES
DONNA M. RYU, Magistrate Judge.
The parties hereby stipulate as follows:
WHEREAS, on or about April 17, 2012, Plaintiffs filed letters with the Court regarding Plaintiffs' issues with Defendant Specialty's Café and Bakery, Inc. and Defendant Craig Saxton's discovery responses. On April 20, 2012, the Court entered an Order requiring the parties to meet and confer regarding the discovery dispute. The parties' current deadline to file a joint letter regarding any discovery disputes is September 7, 2012;
WHEREAS, pursuant to the Court's April 20th Order, the parties have met and conferred on numerous occasions, and have resolved many of their discovery issues. On May 15, 2012, Defendants served amended and supplemental discovery responses. The Defendants also produced additional documents and information in anticipation of the parties' mediation, which took place on June 18, 2012;
WHEREAS, the parties' mediation proved unsuccessful and as a result, the parties have continued to meet and confer regarding the outstanding discovery disputes. As a result of these discussions, Defendants prepared amended responses to discovery requests and produced thousands of documents.
Since July 20, 2012, Defendants have produced:
• all timecard data pertaining to members of the California class, as requested by Plaintiffs' counsel;
• all "coffee break" reports pertaining to members of the California class as requested by Plaintiffs' counsel;
• a report concerning all "dirty invoices" for the entire class period;
• management handbooks;
• documents showing the accounting of tips;
• documents showing the accounting of delivery fees;
• a sample "house floor operations schedule" (based upon agreement with Plaintiffs' counsel); and
• a sample daily deployment chart (based upon agreement with Plaintiffs' counsel). Defendants have also
• served Plaintiffs with Second Amended Responses to Request for Production of Documents, Set Two
• served Plaintiffs with Second Amended Responses to Request for Production of Documents, Set One.
• served Plaintiffs with Third Amended Responses to Request for Production of Documents, Set One
• served Plaintiffs with Third Amended Responses to Request for Production of Documents, Set Two
• served Plaintiffs with First Amended Responses to Request for Production of Documents, Set Three.
By September 11, 2012, Defendants will produce further documents which are responsive to Plaintiffs' requests. By September 12, 2012 Defendants will provide Plaintiffs' counsel with further information regarding TMX.
The parties continue to meet and confer to address outstanding discovery-related issues. These issues include, without limitation, e-mail correspondence and TMX-related data.
The parties have significantly narrowed the discovery-related issues in dispute over the last several months. The parties continue to meet and confer to narrow those issues. Thus, to avoid potentially unnecessary discovery motion practice, the parties request the Court provide the parties with additional time to allow Defendants to modify further their responses and produce additional documents and information. Additionally, the parties request additional time to resolve any outstanding discovery issues that remain thereafter.
IT IS THEREFORE STIPULATED AND AGREED that to the extent there remain any outstanding discovery disputes, the parties' current deadline to file a joint letter shall be continued until September 17, 2012.
IT IS SO STIPULATED.
IT IS HEREBY ORDERED AS FOLLOWS:
To the extent the parties are unable to resolve all discovery disputes through the continued meet and confer process, the parties shall file a joint letter on or before September 17, 2012.
