Filed: May 18, 2017
Latest Update: May 18, 2017
Summary: [PROPOSED] STIPULATED AMENDED DISCOVERY PLAN AND SCHEDULING ORDER PEGGY A. LEEN , Magistrate Judge . SUBMITTED IN COMPLIANCE WITH LR 26-1(b) In accordance with this Court's Scheduling Order [ECF Dkt. 39], on April 28, 2017, the parties met and conferred pursuant Rule 26(f). IT IS HEREBY STIPULATED by and between Plaintiff SUZANNE D. ISHIKAWA ("Plaintiff"), and Defendant EXPERIAN INFORMATION SOLUTIONS, INC., ("Experian"), by and through their counsel of record, hereby submit their stipulat
Summary: [PROPOSED] STIPULATED AMENDED DISCOVERY PLAN AND SCHEDULING ORDER PEGGY A. LEEN , Magistrate Judge . SUBMITTED IN COMPLIANCE WITH LR 26-1(b) In accordance with this Court's Scheduling Order [ECF Dkt. 39], on April 28, 2017, the parties met and conferred pursuant Rule 26(f). IT IS HEREBY STIPULATED by and between Plaintiff SUZANNE D. ISHIKAWA ("Plaintiff"), and Defendant EXPERIAN INFORMATION SOLUTIONS, INC., ("Experian"), by and through their counsel of record, hereby submit their stipulate..
More
[PROPOSED] STIPULATED AMENDED DISCOVERY PLAN AND SCHEDULING ORDER
PEGGY A. LEEN, Magistrate Judge.
SUBMITTED IN COMPLIANCE WITH LR 26-1(b)
In accordance with this Court's Scheduling Order [ECF Dkt. 39], on April 28, 2017, the parties met and conferred pursuant Rule 26(f). IT IS HEREBY STIPULATED by and between Plaintiff SUZANNE D. ISHIKAWA ("Plaintiff"), and Defendant EXPERIAN INFORMATION SOLUTIONS, INC., ("Experian"), by and through their counsel of record, hereby submit their stipulated Amended Discovery Plan and Scheduling Order pursuant to Federal Rule of Civil Procedure 16 and 26, as well as LR II 16-1 and 26-1. It is hereby requested that the Court enter the following discovery plan and scheduling order:
1. Discovery Plan:
Discovery Cut-Off 8/21/2017 (180 days from the date Experian
Information Solutions, Inc., filed its Answer,
2/21/2017)
Deadline to Amend Pleadings 5/22/2017 (90 days prior to the close of
discovery)
Deadline to Disclose Initial Expert 6/21/2017 (60 days prior to
Disclosures the close of discovery)
Deadline to Disclose Rebuttal Expert 7/21/2017 (30 days after
Disclosures the Initial Disclosure of Experts)
Deadline to File Dispositive Motions 9/19/2017 (30 days after the close of
discovery)
2. Interim Status Report: The parties shall file the interim status report required by LR 26-3 no later than 6/21/2017 or sixty-one (60) days prior to the close of discovery.
3. Pre-Trial Order: The parties shall file a joint pretrial order no later than 10/19/2017 or thirty (30) days after the date set for filing dispositive motions. In the event that parties file dispositive motions, the date for filing the joint pretrial order shall be suspended until thirty (30) days after decision on the dispositive motions or further order of the Court. The disclosure required by Federal Rule of Civil Procedure 26(a)(3) and objections thereto shall be made in the pre-trial order.
4. Initial Disclosures: The parties' initial disclosures shall be served on or before 5/12/2017. Any party seeking damages shall comply Federal Rules of Civil Procedure 26(a)(1)(A)(iii).
5. Extension of Discovery Deadline: Requests to extend the discovery shall comply fully with LR 26-4. Applications to extend any date set by the discovery plan, scheduling order, or other order must, in addition to satisfying the requirements of LR IA 6-1, be supported by a showing of good cause for the extension.
The motion or stipulation shall include:
a. A statement specifying the discovery completed by the parties as of the date of the motion or stipulation;
b. A specific description of the discovery which remains to be completed;
c. The reasons why such remaining discovery was not completed within the time limit of the existing discovery deadline; and,
d. A proposed schedule for the completion of all remaining discovery.
It is not good cause for a later request to extend discovery that the parties informally postponed discovery. Any stipulation that would interfere with any time set for completion of discovery, for hearing of a motion, or for trial, may be made only with approval of the Court.
6. Electronically Stored Information ("ESI"):
The Parties stipulate and agree that all discoverable documents will be produced on CD-ROM in Portable Document Format ("PDF") with optical text recognition (electronically searchable text) as reasonably practicable. The Parties further agreed that the "parent-child relationships" between documents will be preserved when documents are produced (e.g., e-mails and their attachments will be produced together with consecutive bates numbers) as reasonably practicable.
While the Parties agree at this time that it is not necessary to produce the metadata for electronic documents, the Parties reserve their respective rights to request such information should any Party deem it necessary. This agreement determines only the format in which the Parties produce documents; it does not affect any other right of any Party.
7. LR II 26-1(b) CERTIFICATIONS: The parties certify that they considered consenting to trial by a magistrate judge and use of the Short Trial Program. The parties further certify that they met and conferred about the possibility of using alternative dispute resolution processes including, mediation, arbitration, and early neutral evaluation.
8. Electronic Service. The Parties agree to accept electronic service of discovery requests and responses pursuant to Federal Rule of Civil Procedure 5(b)(2)(E). The parties discussed whether they intend to present evidence in electronic format to jurors for the purpose of jury deliberations and agreed that should discovery be provided in an electronic format at trial, it will be compatible with the court's electronic jury evidence display system pursuant to LR II 26-1(b)(9).
9. Protective Orders. Any party may seek to enter into a stipulated protective order pursuant to Federal Rule of Civil Procedure 26(c) prior to producing any confidential documents in its possession. A proposed stipulated protective order has been circulated by Plaintiff prior to the discovery conference, has been agreed to by the parties, and will be filed shortly after filing of this proposed discovery plan.
IT IS SO STIPULATED.
SCHEDULING ORDER
The above-set stipulated Amended Discovery Plan of the parties shall be the Scheduling Order for this action pursuant to Federal Rule of Civil Procedure 16(b) and Local Rule 16-1.
