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RABIN v. PricewaterhouseCOOPERS LLP, 16-cv-02276-JST. (2017)

Court: District Court, N.D. California Number: infdco20170308e19 Visitors: 26
Filed: Mar. 07, 2017
Latest Update: Mar. 07, 2017
Summary: STIPULATION AND [PROPOSED] ORDER RE JOINT LETTER BRIEF ON DATA DISCOVERY JON S. TIGAR , District Judge . Plaintiffs Steve Rabin and John Chapman ("Plaintiffs") and Defendant PricewaterhouseCoopers LLP ("PwC") (collectively, "the Parties") hereby stipulate and agree as follows: WHEREAS, on February 16, 2017, Plaintiffs and PricewaterhouseCoopers LLP participated in a telephonic hearing with the Court regarding ongoing discovery disputes; WHEREAS, the Court's Minute Order, ECF No. 72,
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STIPULATION AND [PROPOSED] ORDER RE JOINT LETTER BRIEF ON DATA DISCOVERY

Plaintiffs Steve Rabin and John Chapman ("Plaintiffs") and Defendant PricewaterhouseCoopers LLP ("PwC") (collectively, "the Parties") hereby stipulate and agree as follows:

WHEREAS, on February 16, 2017, Plaintiffs and PricewaterhouseCoopers LLP participated in a telephonic hearing with the Court regarding ongoing discovery disputes;

WHEREAS, the Court's Minute Order, ECF No. 72, instructed the Parties, among other things, to submit a joint letter brief by March 3, 2017 concerning the Parties' dispute regarding Plaintiffs' request for production of data from PwC;

WHEREAS, because one argument asserted by PwC relates to the burden entailed in production of these data, the Parties believe that the briefing will be more useful to the Court after Plaintiffs have taken a deposition of PwC's corporate designee regarding certain topics related to the SourceOne database system, which houses information regarding applicants, including the issue of burden of responding to Plaintiffs' request for data fields;

WHEREAS, the Parties have scheduled the deposition for March 15;

WHEREAS, Plaintiffs have agreed not to seek leave, prior to the deposition, to extend the deposition beyond seven hours;

WHEREAS, the Parties will exchange draft text of the joint letter brief after that deposition, under the following schedule:

Wednesday, March 22: Plaintiffs provide draft text to PwC Wednesday, March 29: PwC provides draft text to Plaintiffs Wednesday, April 5: The Parties file their joint letter with the Court

WHEREAS, because of the complexity of the issues involved, the Parties request that the page limit be extended to a total of ten pages, with each side allowed at most five pages.

THEREFORE, IT IS HEREBY STIPULATED that:

• the Parties will submit a joint letter brief regarding Plaintiffs' request for data discovery by April 5, 2017; and • the page limit is extended to ten pages, with at most five pages allocated per party.

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

ATTESTATION OF SIGNATURE

Pursuant to Civil Local Rule 5-1(i)(3), the filer of this document attests that concurrence in the filing of this document has been obtained from the other signatory above.

Dated: March 2, 2017. OUTTEN & GOLDEN LLP By: /s/Jahan C. Sagafi Jahan C. Sagafi Attorneys for Plaintiffs
Source:  Leagle

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