CAVE CONSULTING GROUP, INC. v. OptumINSIGHT, INC., 3:15-cv-03424-JCS. (2016)
Court: District Court, N.D. California
Number: infdco20160613a95
Visitors: 9
Filed: Jun. 10, 2016
Latest Update: Jun. 10, 2016
Summary: REVISED JOINT PROPOSED SCHEDULE FOR RESOLUTION OF PRIVILEGE AND WORK PRODUCT ISSUES JOSEPH C. SPERO , Magistrate Judge . The parties to this action jointly submit this REVISED JOINT PROPOSED SCHEDULE FOR THE RESOLUTION OF PRIVILEGE AND WORK PRODUCT ISSUES. This document supplements the Joint Proposed Schedule for Resolution of Privilege and Work Product Issues filed April 8, 2016 (ECF No. 81). In the initial Joint Proposed Schedule, the parties submitted competing schedules for docum
Summary: REVISED JOINT PROPOSED SCHEDULE FOR RESOLUTION OF PRIVILEGE AND WORK PRODUCT ISSUES JOSEPH C. SPERO , Magistrate Judge . The parties to this action jointly submit this REVISED JOINT PROPOSED SCHEDULE FOR THE RESOLUTION OF PRIVILEGE AND WORK PRODUCT ISSUES. This document supplements the Joint Proposed Schedule for Resolution of Privilege and Work Product Issues filed April 8, 2016 (ECF No. 81). In the initial Joint Proposed Schedule, the parties submitted competing schedules for docume..
More
REVISED JOINT PROPOSED SCHEDULE FOR RESOLUTION OF PRIVILEGE AND WORK PRODUCT ISSUES
JOSEPH C. SPERO, Magistrate Judge.
The parties to this action jointly submit this REVISED JOINT PROPOSED SCHEDULE FOR THE RESOLUTION OF PRIVILEGE AND WORK PRODUCT ISSUES. This document supplements the Joint Proposed Schedule for Resolution of Privilege and Work Product Issues filed April 8, 2016 (ECF No. 81).
In the initial Joint Proposed Schedule, the parties submitted competing schedules for document production and resolution of privilege and work product issues. Counsel for the parties have conferred, and have agreed to a modified schedule described below:
On or before April 29, 2016: Any party seeking production of information
claimed to be Privileged shall identify (a) the
categories of documents sought and (b) the
scope of any Privilege log it seeks.
— COMPLETED
On or before May 13, 2016: The recipient of the April 29 submission shall
provide notice of areas of agreement or
disagreement as to such submission.
— COMPLETED
On or before June 15, 2016: The parties shall submit a joint disclosure that
identifies any areas of final disagreement
regarding the topics and materials sought to
be produced and logged, and a brief statement
of each party's position supported by relevant
authority.
July 8, 2016: Court hears argument and resolves areas of
(date of next case status conference) disagreement regarding scope of materials for
which privilege logs must be produced
On or before July 15, 2016: The parties shall complete production and
logging of all information as agreed by the
parties and ordered by the Court.
OptumInsight reserves the right to request an
extension to this deadline for the review,
production and privilege logs for (1)
documents from one prior law firm from
which OptumInsight has not yet received any
documents, despite ongoing efforts to collect
those documents; and (2) any broader scope
of documents the Court orders OptumInsight
to review, log and produce at or after the July
8, 2016 status conference. CCGroup reserves
the right to oppose any request for extension
of the deadline.
On or before July 22, 2016: If necessary, the parties shall meet and confer
in person regarding any unresolved issues
concerning the other's production and/or
privilege logs.
No later than July 29, 2016: Either party seeking production of
information withheld on grounds of privilege
or work product shall file a motion to compel.
No later than August 12, 2016, but no later Any Response in opposition to motion to
than two weeks after the moving brief has compel is due.
been filed:
No later than August 18, 2016: Any Reply in support of motion to compel is
due.
September 2, 2016 at 9:30 AM Proposed date of hearing for argument on
motions to compel
September 30, 2016 Mediation
CIVIL L.R. 5-1(i)(3) CERTIFICATION
The undersigned filer of this document hereby certifies that concurrence in the filing of this document has been obtained from the other signatory.
/s/Zachary C. Howenstine
Source: Leagle