Contract analysis

1. WRITTEN DISCOVERY — PHASE I 1.1 Propounding Deadline. All Phase I written discovery shall be propounded (i.e., served) on or before March 1, 2023. The parties acknowledge that both sides have already propounded their Phase I written discovery within this timeframe. 1.2 Response Deadline. All responses and objections to Phase I written discovery shall be served on or before April 15, 2023, unless otherwise agreed i

2. WRITTEN DISCOVERY — PHASE II 2.1 Propounding Deadline. All Phase II written discovery shall be propounded (i.e., served) on or before April 15, 2023. 2.2 Response Deadline. All responses and objections to Phase II written discovery shall be served on or before May 30, 2023, unless otherwise agreed in writing by the parties. 2.3 Scope of Phase II discovery. Phase II discovery shall include supplemental interrogator

3. THIRD-PARTY DISCOVERY 3.1 Third-Party Subpoenas. All third-party subpoenas for business records (non-deposition subpoenas under Code of Civil Procedure section 2020.410) shall be issued on or before February 15, 2023, unless otherwise agreed by the parties or permitted by further order of the Court. The parties acknowledge that Defendant AMA has already issued a third-party subpoena to NovaPay Solutions Inc. on Fe

4. ESI DISCOVERY 4.1 ESI Protocol. All discovery of electronically stored information in this action shall be governed by the ESI Protocol Stipulation and Order entered by this Court on January 13, 2023 (the "ESI Protocol"). To the extent any provision of this Stipulation conflicts with the ESI Protocol, the ESI Protocol shall control with respect to ESI-specific procedures. 4.2 E-discovery Vendor. Defendant AMA has

5. DEPOSITIONS 5.1 Named Plaintiff Depositions. The depositions of the three named Plaintiffs shall be completed within the following schedule: (a) Marisol Fuentes: Deposition to be completed on or before May 15, 2023. (b) Derek Halloran: Deposition to be completed on or before May 15, 2023. (c) Yesenia Padilla: Deposition to be completed on or before May 15, 2023. The parties shall meet and confer in good faith to s

6. EXPERT DISCOVERY (PRE-CERTIFICATION) 6.1 Expert Designation Deadline. Each party shall serve its expert witness designation, identifying all experts the party intends to call in connection with class certification proceedings, on or before March 15, 2023. The designation shall include the subject matter on which each expert is expected to testify and a brief summary of the expert's qualifications, consistent with

7. CLASS CERTIFICATION BRIEFING SCHEDULE 7.1 Plaintiffs' Motion for Class Certification. Plaintiffs shall file and serve their Motion for Class Certification on or before April 14, 2023. Plaintiffs' motion shall include all supporting declarations, expert reports, deposition excerpts, documentary evidence, and other materials upon which Plaintiffs rely in support of certification. 7.2 Putative Class Definition. The p

8. POST-CERTIFICATION DEADLINES 8.1 Post-certification deadlines shall be set by further stipulation of the parties or by order of the Court following the Court's ruling on Plaintiffs' Motion for Class Certification. 8.2 The parties anticipate that if certification is granted, in whole or in part, the following matters will need to be addressed through a supplemental case management schedule: (a) Preparation, approva

9. ALTERNATIVE DISPUTE RESOLUTION 9.1 Agreement to Mediate. The parties agree that mediation is an appropriate and desirable method of alternative dispute resolution in this action. The parties further agree that mediation will be undertaken at an appropriate time following the Court's ruling on Plaintiffs' Motion for Class Certification, so that the mediation may be informed by the Court's certification analysis and

10. TRIAL ESTIMATE 10.1 The parties estimate that if this matter proceeds to trial on the merits following class certification, the trial will require approximately fifteen (15) to twenty (20) court days, including jury selection, opening statements, presentation of evidence, closing arguments, and jury deliberation (if applicable). 10.2 No trial date is being set at this time. A trial date shall be set by further st

11. GENERAL PROVISIONS 11.1 Modification. This Stipulation may be modified by further written stipulation of the parties filed with the Court, or by order of the Court upon noticed motion. No oral modification of this Stipulation shall be effective. 11.2 Extensions. All deadlines set forth herein are subject to extension by mutual written stipulation of the parties, filed with the Court and subject to Court approval.