Filed: Apr. 08, 2015
Latest Update: Apr. 08, 2015
Summary: STIPULATION AND [PROPOSED] ORDER VINCE CHHABRIA , District Judge . Plaintiffs William Michael Hicks and Kenneth Harms, as Class Representative Plaintiffs, et al. (collectively, the "Plaintiffs") and Defendant PGA TOUR, INC. (the "TOUR"), through their respective counsel, hereby stipulate and agree as follows: WHEREAS, this Court entered an order on February 20, 2015 stipulating the parties' agreements with respect to certain scheduling matters in this action (Dkt. 17); WHEREAS, th
Summary: STIPULATION AND [PROPOSED] ORDER VINCE CHHABRIA , District Judge . Plaintiffs William Michael Hicks and Kenneth Harms, as Class Representative Plaintiffs, et al. (collectively, the "Plaintiffs") and Defendant PGA TOUR, INC. (the "TOUR"), through their respective counsel, hereby stipulate and agree as follows: WHEREAS, this Court entered an order on February 20, 2015 stipulating the parties' agreements with respect to certain scheduling matters in this action (Dkt. 17); WHEREAS, the..
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STIPULATION AND [PROPOSED] ORDER
VINCE CHHABRIA, District Judge.
Plaintiffs William Michael Hicks and Kenneth Harms, as Class Representative Plaintiffs, et al. (collectively, the "Plaintiffs") and Defendant PGA TOUR, INC. (the "TOUR"), through their respective counsel, hereby stipulate and agree as follows:
WHEREAS, this Court entered an order on February 20, 2015 stipulating the parties' agreements with respect to certain scheduling matters in this action (Dkt. 17);
WHEREAS, the TOUR moved to transfer venue in this action to the Middle District of Florida on March 5, 2015 (the "Motion") (Dkt. 25);
WHEREAS, Plaintiffs filed a First Amended Complaint on March 16, 2015 (Dkt. 28);
WHEREAS, in connection with the Motion, Plaintiffs have served on the TOUR interrogatories, requests for production, and deposition notices;
IT IS HEREBY STIPULATED AND AGREED that, pursuant to Civil Local Rule 6-1:
1. The TOUR will file any supplemental papers to its Motion to address the new factual allegations and new parties set forth in the First Amended Complaint on or before April 8, 2015;
2. The TOUR will serve Plaintiffs with their responses and objections to Plaintiffs' interrogatories, requests for production, and deposition notices on or before April 8, 2015;
3. The parties will confer no later than April 13, 2015 regarding any objections or disputes in connection with Plaintiffs' discovery requests;
4. In the event that the parties are able to resolve all discovery disputes through the meet-and-confer process:
(a) the TOUR shall produce its answers to interrogatories and document production by May 13, 2015;
(b) depositions in connection with the Motion shall be completed by June 5, 2015;
(c) Plaintiffs' brief in opposition to the Motion shall be due on June 15, 2015;
(d) the TOUR's reply brief shall be due on June 29, 2015; and
(e) the hearing date for the Motion shall be July 16, 2015, or as soon thereafter as the parties may be heard.
5. In the event that there are outstanding discovery disputes that require the Court's resolution:
(a) pursuant to ¶ 14 of the Court's Standing Order for Civil Cases, the parties shall submit a joint letter to the Court stating the nature and status of their dispute;
(b) Plaintiffs shall serve their portion of the joint letter upon the TOUR by April 22, 2015;
(c) the TOUR shall serve its portion of the joint letter upon Plaintiffs by May 1, 2015;
(d) the parties shall file the joint letter on or before May 4, 2014;
(e) the TOUR will produce its answers to interrogatories and document production within 30 days after the Court's resolution of any discovery disputes relating to the Motion;
(f) depositions in connection with the Motion shall be completed within 21 days after the completion of document production;
(g) Plaintiffs shall file their brief in opposition to the Motion within 10 days after the completion of depositions;
(h) the TOUR's reply brief shall be due within 14 days after the filing of Plaintiffs' opposition; and
(i) the hearing date for the Motion shall be on a Thursday no less than 14 days after the filing of Plaintiffs' reply brief;
6. The TOUR will answer, move, or otherwise plead in response to the Complaint within 30 days of the entry of an order on the motion to transfer venue; and
7. In light of the pending Motion, the Case Management Conference and all related deadlines (including the deadlines for the Case Management Statement and ADR Certification) are vacated.
IT IS FURTHER STIPULATED AND AGREED that this Stipulation does not constitute a waiver of any other defense including, but not limited to, the defenses of lack of personal or subject matter jurisdiction or improper venue.
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
