Opinion
No.: 2:10-CV-00291 MCE (GGH)
07-19-2012
CALIFORNIA EARTHQUAKE AUTHORITY, Plaintiff, v. METROPOLITAN WEST SECURITIES, LLC; WACHOVIA BANK, N.A.; and DOES 1 through 25, Defendants.
MICHAEL J. STRUMWASSER (SBN 58413) FREDRIC D. WOOCHER (SBN 96689) PATRICIA T. PEI (SBN 274957) STRUMWASSER & WOOCHER LLP Attorneys for Plaintiff California Earthquake Authority David C. Powell (SBN 129781) Jesse L. Miller (SBN 183229) Christopher C. Foster (SBN 253839) REED SMITH LLP Attorneys for Defendants Metropolitan West Securities, LLC and Wells Fargo Bank, N.A., successor by merger to Wachovia Bank, N.A.
MICHAEL J. STRUMWASSER (SBN 58413)
FREDRIC D. WOOCHER (SBN 96689)
PATRICIA T. PEI (SBN 274957)
STRUMWASSER & WOOCHER LLP
Attorneys for Plaintiff
California Earthquake Authority
David C. Powell (SBN 129781)
Jesse L. Miller (SBN 183229)
Christopher C. Foster (SBN 253839)
REED SMITH LLP
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.
IT IS SO STIPULATED:
REED SMITH LLP
By ________________________
David C. Powell
Jesse L. Miller
Christopher C. Foster
Attorneys for Defendants Metropolitan West
Securities, LLC and Wachovia Bank, N.A.
STRUMWASSER & WOOCHER LLP
By ________________________
Michael J. Strumwasser
Fredric D. Woocher
Patricia T. Pei
Attorneys for Plaintiff California Earthquake
Authority
IT IS SO ORDERED:
________________________
The Honorable Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE