United States District Court, W.D. Washington, Seattle
KATHERINE MOUSSOURIS, HOLLY MUENCHOW, and DANA PIERMARINI, on behalf of themselves and a class of those similarly situated, Plaintiff,
MICROSOFT CORPORATION, Defendant.
FREED SUBIT & THOMAS LLP BY MICHAEL SUBIT ATTORNEYS FOR
PLAINTIFFS AND THE PROPOSED GLASS
ORRICK, HERRINGTON & SUTCLIFFE LLP BY MARK S. PARRIS
ATTORNEYS FOR DEFENDANT
MICROSOFT CORPORATION BY DAVID HOWARD CORPORATE VICE
PRESIDENT AND DEPUTY GENERAL COUNSEL, LITIGATION
JOINT STATEMENT AND [PROPOSED] ORDER RE CLASS DISCOVERY AND BRIEFING
SCHEDULE AND PROPOSED REDACTIONS TO THE COURT'S
JAMES L. ROBART JUDGE
DISCOVERY AND BRIEFING SCHEDULE
to the Court's April 11, 2017 Order (Dkt. # 176) and July
27, 2017 Order (Dkt. # 223), Plaintiffs Katherine
Moussouris, Holly Muenchow and Dana Piermarini, and Defendant
Microsoft Corporation, by and through their respective
counsel, respectfully propose the following class discovery
and class certification deadlines:
deadline for Defendant to complete production of revised
privilege logs pursuant to Special Master Michelle
Peterson's Report and Recommendation [Dkt. No. 196
(preliminarily sealed)] is August 14, 2017.
deadline for the Parties to complete meet and confer on the
completeness of production of the newly-produced documents
and documents flagged by the Special Master in the revised
privilege logs is August 28, 2017. (The Special Master may
complete her work after that date, if needed.)
deadline to complete the two remaining 30(b)(6) depositions -
on the topics of internal gender audits and internal employee
complaints - is September 22, 2017.
deadline for Plaintiffs to file their motion for class
certification and opening expert reports and produce expert
data output to Microsoft is October 27, 2017.
dates for Microsoft to depose Plaintiffs' putative class
member declarants in support of Plaintiffs' class
certification motion are November 6 through 20, 2017.
deadline for Defendant to file its opposition to the motion
for class certification and responding expert reports and
produce its expert data output to Plaintiffs is January 5,
dates for Plaintiffs to depose Microsoft's putative class
member declarants in support of Microsoft's opposition to
Plaintiffs' class certification motion are January 15
through 29, 2018.
deadline for Plaintiffs to file their reply in support of
their motion for class certification and rebuttal ...