The opinion of the court was delivered by: The Honorable Susan Illston United States District Court Judge
STIPULATION AND [PROPOSED] ORDER TO REGARDING DISCOVERY DISPUTES
Plaintiff and Defendant, by and through their undersigned attorneys, hereby enter into the following stipulation and request its approval by the Court.
WHEREAS the parties had various discovery disputes.
WHEREAS the court ordered the parties to further meet and confer.
WHEREAS the parties were able to resolve the below items.
ACCORDINGLY, the parties hereby agree as follows:
Plaintiff's Initial Disclosures and Damages Discovery Responses to Defendant's Interrogatory Nos. 2 and 3:
Plaintiff will provide further information regarding the areas of knowledge of each person listed, update the list of persons with knowledge, and for those former employees of DCAA and Plaintiff's family members, to provide last known contact information. Plaintiff will supplement this information to the same extent that he requested Defendant.
Plaintiff will provide further information regarding damages, including the calculation of such damages, for each and every category claimed and will correct current errors in the damages calculations (e.g., front pay v. back pay, no amounts listed for retirement). To the extent Plaintiff does not seek any monetary amount for any particular category, he will so specify. Where Plaintiff claims in good faith that a calculation is not possible and can never be provided to neither the court nor counsel, Plaintiff will so state with a detailed explanation and reasoning. Plaintiff agrees that for any response it deems to not comply with the parties' agreement, Defendant may move in limine or move to strike the particular damage claim. Both parties reserve objections and arguments.
EDD and SSA Information (Document Requests Nos. 35, 36, 48, 50) In light of the Court's prior order related to discovery of EDD and SSA records of Plaintiff, Plaintiff will produce all EDD and SSA records in his possession, custody and control Verifications Plaintiff will provide any missing verifications for any interrogatory responses.
Plaintiff and his counsel will also conduct another search to ensure that all information relevant 28 to Defendant's discovery requests (including but not limited to Defendant's Document Request Nos. 2, 3, 7, 8, 16, 36, 48-50) in Plaintiff's (including his counsel's) possession, custody and/or control is produced and will provide a written verification(s) based on personal knowledge under penalty of perjury that all such information has been produced.
Privilege Log Plaintiff will produce a supplemental privilege log, if necessary.
Plaintiff will supplement this request to provide all responsive information regarding the employment history of Plaintiff post ...