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Woods v. Google Inc.

United States District Court, Ninth Circuit, California, N.D. California, San Jose Division
Jun 8, 2015
11-cv-1263-EJD (N.D. Cal. Jun. 8, 2015)

Opinion

          KESSLER TOPAZ MELTZER & CHECK, LLP, Stacey M. Kaplan, San Francisco, CA, and Sean M. Handler, (Pro Hac Vice) Matthew L. Mustokoff, (Pro Hac Vice) Ryan T. Degnan, (Pro Hac Vice) Margaret E. Onasch, (Pro Hac Vice) Daniel C. Mulveny, (Pro Hac Vice) Radnor, PA, NIX, PATTERSON & ROACH, LLP, Jeffrey J. Angelovich, (Pro Hac Vice) Brad E. Seidel, (Pro Hac Vice) Andrew G. Pate, (Pro Hac Vice) Chad E. Ihrig, (Pro Hac Vice) Austin, TX, Interim Co-Class Counsel.

          MAYER BROWN LLP, Edward D. Johnson, Donald M. Falk, Eric B. Evans, Dominique-Chantale Alepin, Two Palo Alto Square, Palo Alto, CA, Attorneys for Defendant Google Inc.


          JOINT STIPULATION AND [PROPOSED] ORDER REGARDING EXPERT DISCOVERY

          EDWARD J. DAVILA, District Judge.

         Plaintiff Rick Woods and Defendant Google Inc., by and through their counsel of record herein, hereby stipulate and agree, subject to Court approval, to the following regarding the scope of discovery and testimony relating to experts in this matter:

         WHEREAS, in order to avoid consuming the parties' and the Court's time and resources on potential discovery issues relating to experts, the parties have agreed to certain limitations on the scope of expert-related discovery and testimony in this matter.

         IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff and Defendant and subject to Court approval, as follows:

         The following categories of data, information, or documents need not be disclosed by any party, and are outside the scope of permissible discovery (including deposition questions):

         1. Any notes or other writings taken or prepared by or for an expert witness in connection with this matter, including correspondence or memos to or from, and notes of conversations with any person, including, but not limited to, the expert's assistants and/or clerical or support staff, other fact or expert witnesses or non-testifying expert consultants, or attorneys for the party offering the testimony of such expert witness, unless the expert witness relies on those notes or other writings in connection with the expert witness' opinions in this matter; and

         2. Any oral or written communication between an expert witness and any person, including, but not limited to, the expert's assistants and/or clerical or support staff, other fact or expert witnesses or non-testifying expert consultants, or attorneys for the party offering the testimony of such expert witness, unless the expert witness relies on those oral or written communications in connection with the expert witness' opinions in this matter.

         IT IS SO STIPULATED

         IT IS SO ORDERED.


Summaries of

Woods v. Google Inc.

United States District Court, Ninth Circuit, California, N.D. California, San Jose Division
Jun 8, 2015
11-cv-1263-EJD (N.D. Cal. Jun. 8, 2015)
Case details for

Woods v. Google Inc.

Case Details

Full title:RICK WOODS, Individually and on Behalf of All Others Similarly Situated…

Court:United States District Court, Ninth Circuit, California, N.D. California, San Jose Division

Date published: Jun 8, 2015

Citations

11-cv-1263-EJD (N.D. Cal. Jun. 8, 2015)