govinfo:USCOURTS-cand-3_24-cv-06994-2

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1 
JOINT STIPULATION AND [PROPOSED] ORDER REVISING CASE MANAGEMENT SCHEDULE 
3:24-cv-06994-EMC 
Geoffrey Graber (SBN 211547)ௗ 
Madelyn Petersen (pro hac vice) 
COHEN MILSTEIN 
SELLERS & TOLL PLLCௗ 
1100 New York Ave. NW, Suite 800 
Washington, DC 20005ௗ 
Telephone: (202) 408-4600ௗ 
Facsimile: (202) 408-4699 
ggraber@cohenmilstein.comௗ 
mpetersen@cohenmilstein.comௗ 
 
Charles Reichmann (SBN 206699)ௗௗ 
LAW OFFICES OF 
CHARLES REICHMANNௗ 
16 Yale Circleௗ 
Kensington, CA 94708-1015ௗ 
Telephone: (415) 373-8849ௗ 
charles.reichmann@gmail.comௗ 
 
Attorneys for Plaintiffs 
 
[Additional counsel listed on signature page] 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
CHASE BOURQUE, RENEE BAUTISTA, 
MELISSA MIRABELLO, RON 
POZNANSKY, and JAMES 
WOODMANSEE, individually and on behalf 
of all others similarly situated¸ 
Plaintiffs, 
vs. 
UNITED STATES OF AMERICA and 
UNITED STATES DEPARTMENT OF 
STATE, 
Defendants. 
 
 

 
JOINT STIPULATION AND [PROPOSED] 
ORDER REVISING CASE MANAGEMENT 
SCHEDULE 
 
 
Hon. Edward M. Chen 1
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2 
JOINT STIPULATION AND [PROPOSED] ORDER REVISING CASE MANAGEMENT SCHEDULE 
3:24-cv-06994-EMC 
Pursuant to Civil Local Rule 6-2, the parties in the above-captioned litigation, by and through 
their undersigned counsel, stipulate as follows: 
1. On December 15, 2025, the Court granted the parties’ proposed revised case 
management schedule following the resumption of appropriations to the Federal Government. See 
ECF No. 94. Pursuant to that schedule, the current fact discovery cutoff deadline is May 14, 2026, and 
the current deadline for expert disclosures is May 21, 2026. 
2. The parties have diligently sought to complete fact discovery by the current May 14, 
2026 cutoff date. The parties have largely completed written discovery, with the following exceptions: 
a. Defendants plan to respond to Plaintiffs’ most recent set of Interrogatories by the 
current deadline of May 11, 2026. Plaintiffs plan to respond to Defendants’ 
Requests for Admission and most recent Requests for Production and 
Interrogatories by the current deadline of May 14, 2026. 
b. The Parties have been working to raise and resolve Plaintiffs’ challenges to 
Defendants’ privilege assertions. On March 2, 2026, the Parties filed a joint letter 
brief regarding Plaintiffs’ challenge to De fendants’ assertion of the deliberative 
process privilege for a set of documents identified on Defendants’ privilege logs. 
ECF No. 110. On April 1, 2026, the parties submitted a second joint letter brief, 
and Defendants provided an in camera submission of a subset of those documents, 
pursuant to the Magistrate Judge’s Order of March 12, 2026. See ECF No. 129. The 
Magistrate Judge’s decision remains pending. 
c. The parties are continuing to discuss certain objections raised by Plaintiffs to 
Defendants’ responses to Plaintiffs’ Requests for Production. In connection with 
that discussion, Plaintiffs may serve an additional Interrogatory requesting limited 
additional information. 
3. In regard to depositions, Plaintiffs have sought Rule 30(b)(6) testimony, but the parties 
are in discussions in an attempt to narrow the scope of the requested testimony. On April 14, 2026, 
Plaintiffs indicated they would seek deposition testimony from four additional Department employees 
(one of whom is a former employee). Defendants do not believe this additional deposition testimony 

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3 
JOINT STIPULATION AND [PROPOSED] ORDER REVISING CASE MANAGEMENT SCHEDULE 
3:24-cv-06994-EMC 
is needed to address Plaintiffs’ claims, particularly given the scope of topics Plaintiffs seek to address 
in a 30(b)(6) deposition. However, the parties are in discussions in an attempt to narrow the testimony 
sought so as to avoid raising a dispute with the Court. The parties are also in discussions regarding the 
deposition of Plaintiffs’ Confidential Witness. 
4. In regard to expert testimony, Defendants believe the Court’s rulings on Plaintiffs’ 
Motion for Class Certification and Defendants’ Motion to Exclude the expert declaration that Plaintiffs 
submitted with their class certification filing may inform the parties’ further decisions regarding what, 
if any, expert testimony will be offered. 
5. Accordingly, the parties propose a 45-day extension of the fact discovery cutoff date 
for the limited purpose of addressing the above-referenced outstanding issues, including the 
scheduling and taking of up to six depositions, and, if needed, raising remaining outstanding disputes 
with the Magistrate Judge. 
6. The parties propose that the remaining deadlines in the case be extended as follows: 
 
Event Previous Deadline 
 
Proposed Deadline 
 
Non-Expert Discovery Cutoff 
 
Thursday, May 14, 2026 
 
June 26, 2026 
Expert Disclosures 
 
Thursday, May 21, 2026 
 
July 20, 2026 
Rebuttal Expert Disclosure 
 
Thursday, June 11, 2026 
 
August 24, 2026 
Reply Expert Disclosure 
 
Thursday, June 25, 2026 
 
September 11, 2026 
Close of Expert Discovery 
 
Thursday, July 9, 2026 
 
September 24, 2026 
Dispositive Motions and/or 
Daubert Briefing 
 
Thursday July 16, 2026, 
Deadline for Motions 
 
Thursday August 13, 2026, 
Deadline for Oppositions 
 
Thursday August 27, 2026, 
Deadline for Replies 
 
October 1, 2026 
Deadline for Plaintiffs’ 
summary judgment motion 
and/or Daubert briefing 
 
October 29, 2026 
Deadline for Defendants’ 
combined summary judgment 
motion and/or Daubert 
briefing and opposition to 
Plaintiffs’ briefing 1
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4 
JOINT STIPULATION AND [PROPOSED] ORDER REVISING CASE MANAGEMENT SCHEDULE 
3:24-cv-06994-EMC 
November 12, 2026 
Deadline for Plaintiffs’ 
combined reply and 
opposition to Defendants’ 
motion 
 
December 3, 2026 
Deadline for Defendants’ 
repl
y 
Hearing on Dispositive 
Motions and/or Daubert 
Briefing 
 
Thursday, September 24, 2026 
 
 
January 14, 2027 
7. Pursuant to local rule 6-2(a), this stipulated request is supported by the accompanying 
declaration from Geoffrey Graber, Interim Class Counsel. 
8. IT IS HEREBY STIPULATED AND AGREED, subject to the Court’s approval, that 
the below deadlines are extended and reset as follows: 
 
Event Deadline 
Non-Expert Discovery Cutoff June 26, 2026 
Expert Disclosures July 20, 2026 
Rebuttal Expert Disclosure August 24, 2026 
Reply Expert Disclosure September 11, 2026 
Close of Expert Discovery September 24, 2026 
Dispositive Motions and/or Daubert Briefing 
 
Plaintiffs’ Dispositive/Daubert Motions: 
October 1, 2026 
 
Defendants’ Combined Dispositive/Daubert 
Motions & Oppositions: October 29, 2026 
 
Plaintiffs’ Dispositive/Daubert Oppositions & 
Replies: November 12, 2026 
 
Defendants’ Replies: December 3, 2026 
 
Hearing on Dispositive Motions and/or Daubert 
Briefing 
January 14, 2027 
 
 
 
 

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5 
JOINT STIPULATION AND [PROPOSED] ORDER REVISING CASE MANAGEMENT SCHEDULE 
3:24-cv-06994-EMC 
Dated: May 1, 2026 Respectfully submitted, 
 
BRETT A. SHUMATE 
Assistant Attorney General 
 
/s/ Geoffrey Graber 
 
STEPHEN M. ELLIOTT 
Assistant Director, Federal Programs 
Branch 
 
 Geoffrey Graber (SBN 211547) ௗௗ 
Madelyn Petersenௗ(pro hac vice) 
COHEN MILSTEIN ௗ 
SELLERS & TOLL PLLCௗ 
1100 New York Ave. NW, Suite 800 
Washington, DC 20005ௗ 
Telephone: (202) 408-4600ௗ 
Facsimile: (202) 408-4699 
ggraber@cohenmilstein.comௗ 
mpetersen@cohenmilstein.com 
 
Charles Reichmannௗ(SBN 206699)ௗ 
LAW OFFICES OF ௗ 
CHARLES REICHMANNௗ 
16 Yale Circleௗ 
Kensington, CA 94708-1015ௗ 
Telephone: (415) 373-8849ௗ 
charles.reichmann@gmail.comௗ 
 
Mariel LaSasso (pro hac vice) 
LASASSO LAW GROUP PLLC 
30 Wall St., Eighth Floor 
New York, NY 10005 
Telephone: (212) 421-6000 
mariel@lasassolaw.com 
 
Interim Class Counsel 
/s/ Kathryn L. Wyer 
 
JESSICA A. LUNDBERG 
Trial Attorney 
KATHRYN L. WYER 
Senior Trial Counsel 
Civil Division, Federal Programs Branch 
U.S. Department of Justice 
1100 L Street NW 
Washington, DC 20005 
 
Counsel for Defendants 
 
 
 
 

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6 
JOINT STIPULATION AND [PROPOSED] ORDER REVISING CASE MANAGEMENT SCHEDULE 
3:24-cv-06994-EMC 
CIVIL L.R. 5-1(i)(3) ATTESTATION 
Pursuant to Civil Local Rule 5-1(i)(3) regarding signatures, I attest that concurrence in the 
filing of this document has been obtained from all signatories. 
 
Dated: May 1, 2026 /s/ Geoffrey Graber 1
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7 
JOINT STIPULATION AND [PROPOSED] ORDER REVISING CASE MANAGEMENT SCHEDULE 
3:24-cv-06994-EMC 
 ORDER 
PURSUANT TO STIPULATION, it is so ordered. 
DATED: 
HON. EDWARD M. CHEN 
United States District Judge 

May 14, 2026

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