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K.H. v. The Secretary of the Department of Homeland Security, 15-cv-02740 JST. (2016)

Court: District Court, N.D. California Number: infdco20160818b02 Visitors: 7
Filed: Aug. 16, 2016
Latest Update: Aug. 16, 2016
Summary: STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE JON S. TIGAR , District Judge . The parties respectfully request a three-week extension of the current case deadlines. (ECF 42.) The parties have been working diligently to move this case along. Since the last conference with the Court: both sides have propounded and responded to additional, written discovery; defendants have produced over 12,000 pages of documents; 5 depositions have been taken (3 Federal Air Marshals, and 2 ma
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STIPULATION AND [PROPOSED] ORDER REGARDING CASE SCHEDULE

The parties respectfully request a three-week extension of the current case deadlines. (ECF 42.) The parties have been working diligently to move this case along. Since the last conference with the Court: both sides have propounded and responded to additional, written discovery; defendants have produced over 12,000 pages of documents; 5 depositions have been taken (3 Federal Air Marshals, and 2 management representatives); the class list has been compiled and, on August 5, 2016, class notice was mailed out. Notwithstanding these efforts, some unanticipated delay has occurred with respect to plaintiff's retention of an expert and the process of getting the expert's background checked and Transportation Security Administration clearance to receive Sensitive Security Information. Accordingly, plaintiffs need an additional three weeks to prepare their expert report. Defendant has no objection to a three-week extension, provided that all related case deadlines move in tandem. The parties thus respectfully request that the Court re-set the current case deadlines as follows:

SCHEDULE EVENT CURRENT DATE NEW DATE Plaintiffs' Expert Disclosures August 15, 2016 September 6, 2017 (FRCP 26(a)(2)) Defendant's Expert Disclosures October 17, 2016 November 7, 2017 (FRCP 26(a)(2)) Deadline for Dispositive Motion December 2, 2016 December 23, 2016 Depositions Filing Deadline for Defendant's January 13, 2017 February 3, 2017 Summary Judgment Motion (under seal, redacted version filed within 30 days)1 Filing Deadline for Plaintiff's February 10, 2017 March 3, 2017 Opposition to Defendant's Summary Judgment Motion (under seal, redacted version filed within 30 days) Filing Deadline for Defendant's March 8, 2017 March 29, 2017 Reply in Support of Summary Judgment Motion (under seal, redacted version filed within 30 days) Hearing on Defendant's Summary March 30, 2017 at 2:00 p.m. April 20, 2017 at 2:00 p.m. Judgment Motion

[PROPOSED] ORDER

Pursuant to the parties' stipulation, IT IS SO ORDERED.

FootNotes


1. Many of the documents regarding the Federal Air Marshal Service's operations contain Sensitive Security Information ("SSI"), as defined by federal regulation, 49 C.F.R. § 1520.5. TSA has a SSI Program Office that reviews court filings for SSI redaction. See generally 49 C.F.R. § 1520.5. Otherwise, "records containing SSI are not available for public inspection or copying." 49 C.F.R. § 1520.15. In order to protect this SSI, the parties request that they initially be permitted to file their class certification briefing under seal. Both sides' briefs will then be reviewed by the SSI Program Office for redactions, and publicly-available versions filed within 30 days.
Source:  Leagle

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