Free Case Management Statement - District Court of California - California

Case 3:08-cv-02845-WHA

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HANSON BRIDGETT LLP DIANE MARIE O'MALLEY - 139166 [email protected] JAHMAL T. DAVIS - 191504 [email protected] 425 Market Street, 26th Floor San Francisco, CA 94105 Telephone: (415) 777-3200 Facsimile: (415) 541-9366 Attorneys for Defendant GOLDEN GATE BRIDGE, HIGHWAY AND TRANSPORTATION DISTRICT KAHN BROWN & POORE LLP DAVID M. POORE, ESQ. [email protected] 755 Baywood Drive, Suite 185 Petaluma, California 94954 Telephone: (707) 763-7100 Facsimile: (707) 763-7180 Attorney for Plaintiff DOUGLAS ALARID

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (San Francisco)

DOUGLAS ALARID, Plaintiff, v. GOLDEN GATE BRIDGE HIGHWAY AND TRANSPORTATION DISTRICT; MICHAEL LOCATI; DAVID RIVERA; KAY WITT, and DOES 1 through 50, inclusive, Defendants.

No. CV-08-02845-WHA RULE 26(f) REPORT Action Filed: Action Removed: March 28, 2008 June 6, 2008

Pursuant to Fed. Rule. Civ. Proc. 26(f), counsel for Plaintiff, David Poore, and counsel for Defendant, Diane Marie O'Malley conducted a telephonic conference on September 3, 2008. The Parties now jointly submit this Report detailing the meet-and-confer discussions and plan for
RULE 26(F) REPORT (CASE NO. CV-08-02845-WHA)
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discovery in compliance with Fed. Rule Civ. Proc. 26(f)(2). DISCOVERY PLAN: The Parties jointly propose to the Court the following discovery plan: 1. Pre-Discovery Disclosures FRCP 26(f)(3)(A):

No changes were made in the timing, form, or requirement for disclosures under Rule 26(a). The parties exchanged the information required by Rule 26(a)(1) on September 3, 2008. 2. Scope And Deadlines For Discovery FRCP 26(f)(3)(B):

The Parties agree that discovery will be necessary on all subjects related to the allegations and prayer for relief in Plaintiff's Complaint, as well as the denials, affirmative defenses and prayer in Defendant's Answer. These subjects will include, but not be limited to, Plaintiff's employment, job schedule, outside employment, request for leave, job promotion and harassment complaint while employed at the District and the damages allegedly suffered by Plaintiff. The Parties further agree that discovery should be completed by August 2009, and should comply with the Federal Rules of Civil Procedure, unless the Parties stipulate or agree to do otherwise. 3. Discovery of Electronically Stored Information FRCP 26(f)(3)(C):

The Parties do not anticipate any issues regarding the disclosure or discovery of electronically stored information. To the extent that any such discovery is needed, the Parties agree to comply with Federal Rule of Civil Procedure 26(b)(2). Both Parties have fulfilled their duties to preserve electronically stored information. 4. Privileged and Protected Material FRCP 26(f)(3)(D):

While the Parties do not anticipate any issues or disputes regarding the discovery of privileged or protected materials, they agree to identify and assert any such claim to privilege on a privilege log as required pursuant to Federal Rule of Civil Procedure 26(b)(5). The Parties further agree to use the process provided in Rule 26(b)(5)(B) to address any concerns related to inadvertently disclosed information subject to privilege or privacy. ///// -2RULE 26(F) REPORT (CASE NO. CV-08-02845-WHA)
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5.

No Changes to the Statutory Discovery Limitations FRCP 26(f)(3)(E):

No changes were made in the limitations on discovery imposed under Rule 26. 6. Expert Discovery FRCP 26(f)(3)(F):

The Parties agree that expert discovery will proceed pursuant to Rule 26(a)(2) and that reports from retained experts, if any, will be due: September 2009.

DATED:

September 3, 2008

HANSON BRIDGETT LLP

By:

/s/ Diane Marie O'Malley DIANE MARIE O'MALLEY JAHMAL T. DAVIS Attorneys for Defendant GOLDEN GATE BRIDGE HIGHWAY AND TRANSPORTATION DISTRICT KAHN BROWN & POORE LLP

DATED:

September 3, 2008

By:

/s/ David M. Poore DAVID M. POORE Attorneys for Plaintiff DOUGLAS ALARID

-3RULE 26(F) REPORT (CASE NO. CV-08-02845-WHA)
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