Filed: Feb. 18, 2016
Latest Update: Feb. 18, 2016
Summary: JOINT CASE MANAGEMENT REPORT JON S. TIGAR , District Judge . Plaintiff, Michael Rodman ("Plaintiff") and Defendant, Safeway Inc. ("Safeway") submit this Status Report to provide an update on three issues currently pending before this Court, which are: the bill of costs; a proposed interim notice to Class Members of entry of the judgment; and a briefing schedule for Plaintiff's anticipated motion for discovery sanctions. The parties are filing concurrently herewith two stipulations that, sub
Summary: JOINT CASE MANAGEMENT REPORT JON S. TIGAR , District Judge . Plaintiff, Michael Rodman ("Plaintiff") and Defendant, Safeway Inc. ("Safeway") submit this Status Report to provide an update on three issues currently pending before this Court, which are: the bill of costs; a proposed interim notice to Class Members of entry of the judgment; and a briefing schedule for Plaintiff's anticipated motion for discovery sanctions. The parties are filing concurrently herewith two stipulations that, subj..
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JOINT CASE MANAGEMENT REPORT
JON S. TIGAR, District Judge.
Plaintiff, Michael Rodman ("Plaintiff") and Defendant, Safeway Inc. ("Safeway") submit this Status Report to provide an update on three issues currently pending before this Court, which are: the bill of costs; a proposed interim notice to Class Members of entry of the judgment; and a briefing schedule for Plaintiff's anticipated motion for discovery sanctions. The parties are filing concurrently herewith two stipulations that, subject to Court approval, resolve the issues concerning the bill of costs and the proposed interim notice. The parties have also agreed to a briefing schedule for Plaintiff's motion for sanctions, which is set forth below. As such, the parties believe the Case Management Conference currently scheduled for February 24, 2016 can be taken off calendar. Alternatively, Plaintiff will file herewith a request to appear telephonically.
A. Bill of Costs
The parties have reached agreement on a stipulated amount of $95,000.00 for Plaintiff's Bill of Costs incurred through the date of the approximately $41.9 million judgment. The parties are submitting a stipulation to that effect today.
B. Notice of Entry of Judgment to Class Members
The parties have agreed to send a notice to class members to provide them with an update on the status of the case, and also reminding Class members that they should contact Class counsel in the event that their address or contact information changes prior to resolution of the litigation. The parties have agreed on the content of the notice and manner of distribution, and are submitting a stipulation and proposed order seeking approval today.
C. Plaintiff's Motion for Sanctions
The parties have engaged in meet and confer discussions regarding Plaintiff's anticipated motion for discovery sanctions but have been unable to reach any agreement that obviates the need to file the motion. The parties propose the following briefing schedule:
March 16, 2016 — Deadline for Plaintiff to file motion for sanctions
April 13, 2016 — Deadline for Defendant to respond
May 4, 2016 — Plaintiff's Reply
May 19, 2016 (or such other date as the Court may choose) — Hearing on Plaintiff's motion for sanctions
A proposed order setting the above schedule is attached hereto.
[PROPOSED] ORDER
The Court sets the following deadline for Plaintiff's anticipated Motion for Discovery Sanctions:
March 16, 2016 Deadline for Plaintiff to file motion for sanctions
April 13, 2016 Deadline for Defendant to respond
May 4, 2016 Plaintiff's Reply
May 26, 2016 Hearing on Plaintiff's motion for sanctions
IT IS SO ORDERED.
