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Harris v. Vector Marketing Corp.

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA


June 17, 2010

ALICIA HARRIS, AS AN INDIVIDUAL AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
VECTOR MARKETING CORPORATION, A PENNSYLVANIA CORPORATION; AND DOES 1 THROUGH 20, INCLUSIVE, DEFENDANTS.

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,

Courtroom C

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 dchang@diversitylaw.com chubble@diversitylaw.com lwlee@diversitylaw.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.

IT SO STIPULATED.

Dated: June 16, 2010

MARLIN & SALTZMAN Christina A. Humphrey, Esq. Attorneys for Plaintiff

Dated: June 16, 2010

REED SMITH, LLP Roxanne Wilson, Esq. Attorneys for Defendant

I, Christina A. Humphrey, attest that I have obtained concurrence from Roxanne Wilson in the filing of this Stipulation. See N.D. Cal. General Order 45 § 10(B).

GOOD CAUSE APPEARING, IT IS SO ORDERED,

20100617

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