The opinion of the court was delivered by: Honorable Edward M. Chen
JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING FRCP 30 LIMITATION ON NUMBER OF DEPOSITIONS AND FRCP 33 LIMITATION ON NUMBER OF INTERROGATORIES Assigned to the Hon. Edward M. Chen,
ADDITIONAL PLAINTIFF'S COUNSEL Daniel H. Chang, Esq. (SBN 183803) Craig S. Hubble, Esq. (SBN 200789) Larry W. Lee, Esq. (SBN 228175) DIVERSITY LAW GROUP 444 S. Flower Street Citigroup Center, Suite 1370 Los Angeles, California 90071 Telephone: (213) 488-0655 Facsimile: (213) 488-6554 email@example.com firstname.lastname@example.org email@example.com Sherry Jung, Esq. (SBN 234406) LAW OFFICES OF SHERRY JUNG 448 S. Hill St., Ste. 605 Los Angeles, California 90013 Telephone: (213) 489-8900 Facsimile: (213) 489-8915 Sherryj23@hotmail.com
Plaintiff Alicia Harris ("Plaintiff") and Defendant, Vector Marketing Corp. ("Defendant"), by and through their counsel of record, hereby stipulate and agree as follows:
WHEREAS, FRCP 30(a)(2)(A)(i) provides that only ten (10) depositions may be taken by each party throughout the course of a case;
WHEREAS, FRCP 33(a)(1) provides that only twenty-five (25) special interrogatories may be propounded by each party throughout the course of a case;
WHEREAS, given the number of special interrogatories already propounded and the number of depositions already conducted by the parties in relation to Defendant's Summary Judgment Motion previously filed, the parties have met and conferred and agree that the ten (10) deposition limit and the twenty-five (25) interrogatory limit will not provide the parties with sufficient discovery to adequately brief the issues relating to class certification;
IT IS HEREBY STIPULATED by the parties herein, through their counsel of record, as follows:
1. In addition to the ten (10) depositions allocated to each party pursuant to FRCP 30(a)(2)(A)(1), the number of depositions which may be taken to prepare for the filing of Plaintiff's class certification motion and/or final FLSA certification, without leave of court or further stipulation, is ten (10) depositions per party;
2. In addition to the twenty-five (25) interrogatories allocated to each party pursuant to FRCP 33(a)(1), the number of special interrogatories which may be propounded to prepare for the filing of Plaintiff's class certification motion and/or final FLSA certification, without leave of court or further stipulation, shall be fifteen (15) special interrogatories.
MARLIN & SALTZMAN Christina A. Humphrey, Esq. ...