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Moussouris v. Microsoft Corp.

United States District Court, W.D. Washington, Seattle

August 10, 2017

KATHERINE MOUSSOURIS, HOLLY MUENCHOW, and DANA PIERMARINI, on behalf of themselves and a class of those similarly situated, Plaintiff,
v.
MICROSOFT CORPORATION, Defendant.

          FRANK 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 ORDER

          HON. JAMES L. ROBART JUDGE

         CLASS DISCOVERY AND BRIEFING SCHEDULE

         Pursuant 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:

         1. The 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.

         2. The 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.)

         3. The 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.

         4. The 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.

         5. The dates for Microsoft to depose Plaintiffs' putative class member declarants in support of Plaintiffs' class certification motion are November 6 through 20, 2017.

         6. The 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, 2018.

         7. The 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.

         8. The deadline for Plaintiffs to file their reply in support of their motion for class certification and rebuttal ...


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