The opinion of the court was delivered by: The Honorable Gregory G. Hollows United States Magistrate Judge
M ICHAEL J. S TRUMWASSER (SBN 58413) F REDRIC D. W OOCHER (SBN 96689) P ATRICIA T. P EI (SBN 274957) STRUMWASSER & WOOCHER LLP 10940 Wilshire Boulevard, Suite 2000 Los Angeles, California 90024 Tel.: (310) 576-1233 Fax: (310) 319-0156 E-mail: email@example.com firstname.lastname@example.org email@example.com Attorneys for Plaintiff California Earthquake Authority David C. Powell (SBN 129781) Email: firstname.lastname@example.org Jesse L. Miller (SBN 183229) Email: email@example.com Christopher C. Foster (SBN 253839) Email: CFoster@reedsmith.com REED SMITH LLP 101 Second Street, Suite 1800 San Francisco, CA 94105-3659 Telephone: 415 543 8700 Facsimile: 415 391 8269 Attorneys for Defendants Metropolitan West Securities, LLC and Wells Fargo Bank, N.A., successor by merger to Wachovia Bank, N.A.
STIPULATION AND ORDER ON PARTIES' LIMITED PROTECTIVE ORDER AND PROTOCOL
Date action removed: February 4, 2010 Trial date: October 7, 2013
WHEREAS, Plaintiff California Earthquake Authority ("CEA") and Defendants Metropolitan West Securities LLC ("MetWest") and Wells Fargo Bank, N.A., successor by merger to Wachovia Bank, N.A. (collectively, "Defendants") have been meeting and conferring in good faith to finalize a protective order and discovery protocol regarding the data contained on Defendants' last backup tape of defendants' prior e-mail system ("MetWest GroupWise Backup Tape");
WHEREAS, the parties submitted a stipulation on July 3, 2012 anticipating that a minimum of two additional weeks would be needed to locate and retrieve the tape and obtain technical information regarding the cost of the restoration of the MetWest GroupWise Backup Tape, and the Court granted that stipulation on July 6, 2012;
WHEREAS, Defendants have located and obtained the MetWest GroupWise Backup Tape, but do require additional time to obtain technical information regarding the cost of its restoration;
WHEREAS, the parties anticipate that three additional weeks will be necessary in order to obtain that technical information and finalize the discovery protocol;
NOW, THEREFORE, IT IS HEREBY STIPULATED by and among Plaintiff California Earthquake Authority and Defendants Metropolitan West Securities, LLC and Wachovia Bank, N.A., through the undersigned counsel, that the parties be permitted an additional three weeks within which to reach an agreement on the limited discovery protocol. The parties shall file the Backup Tape Protocol and Protective Order as soon as practicable but in no case later than Tuesday, August 7, 2012 without further order of the Court.
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