Opinion
No.: 2:10-CV-00291 MCE (GGH)
07-05-2012
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
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 reach a protocol governing the discovery issues remaining in this case;
WHEREAS, the parties submitted a stipulation on June 29, 2012 that was signed by this Court on July 3, 2012, which left the issue of the protocol and protective order to govern the production of data from the most recent MetWest GroupWise backup tape to the CEA open subject to further negotiations ("Backup Tape Protocol and Protective Order");
WHEREAS, the parties' agreement contemplated that the parties would continue to meet and confer in good faith regarding the Backup Tape Protocol and Protective Order, and that the parties would be able to reach a final agreement on the Backup Tape Protocol and Protective Order by July 3, 2012;
WHEREAS, the parties have continued to meet and confer in good faith on the Backup Tape Protocol and Protective Order;
WHEREAS, the parties have determined that they need to obtain additional technical information regarding the restoration of the MetWest GroupWise backup tape before they can reach a final agreement on the Backup Tape Protocol and Protective Order;
WHEREAS, the necessary technical information regarding the restoration of the MetWest GroupWise backup tape will not be available to the parties for a minimum of two weeks;
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 two weeks within which to reach an agreement on the limited discovery protocol to govern the production of the most recent MetWest GroupWise backup tape. The parties shall file the Backup Tape Protocol and Protective Order on or before Tuesday, July 17, 2012.
IT IS SO STIPULATED:
REED SMITH LLP
By Christopher Foster
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 Patricia Pei
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