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Case No. 3:16-cv-07014-VC

PLAINTIFF OBOT’S DEPOSITION AND DISCOVERY DESIGNATIONS

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

 Robert P. Feldman (Bar No. 69602) 

 bobfeldman@quinnemanuel.com 

 David Myre (Bar No. 304600) 

 davidmyre@quinnemanuel.com 

555 Twin Dolphin Drive, 5th Floor 

Redwood Shores, California 94065-2139 

Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

 Meredith M. Shaw (Bar No. 284089) 

 meredithshaw@quinnemanuel.com 

50 California Street, 22nd Floor 

San Francisco, CA 94111 

Telephone: (415) 875-6600 

Attorneys for Plaintiff 

OAKLAND BULK & OVERSIZED TERMINAL, LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

OAKLAND BULK & OVERSIZED 

TERMINAL, LLC 

Plaintiff, 

vs. 

CITY OF OAKLAND, 

Defendant. 

 Case No. 3:16-cv-07014-VC 

PLAINTIFF OAKLAND BULK & 

OVERSIZED TERMINAL, LLC’S 

DEPOSITION AND DISCOVERY 

DESIGNATIONS 

Ctrm: No. 2, 17th Floor 

Judge: Honorable Vince Chhabria 

Trial: January 16, 2018 

Case 3:16-cv-07014-VC Document 213 Filed 01/09/18 Page 1 of 2
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-1- Case No. 3:16-cv-07014-VC

 PLAINTIFF OBOT’S DEPOSITION AND DISCOVERY DESIGNATIONS

Pursuant to Paragraph 37 of the Court’s Standing Order for Civil Jury Trials, Plaintiff 

Oakland Bulk & Oversized Terminal, LLC (“OBOT”) respectfully submits these discovery 

designations. Attached hereto as Exhibit A are OBOT’s deposition designations, Defendants’ 

objections and counter-designations, and OBOT’s respective counter-counter-designations and 

objections for the following witnesses (along with a key describing the abbreviations used for 

OBOT’s objections): 

Witness 

Doug Cole, Project Manager, City of Oakland

Sabrina Landreth, City Administrator, City of Oakland 

Stephen Sullivan, City of Oakland Expert Witness

James Wolff, Chief Financial Officer, Bowie Resource Partners 

Additionally, attached hereto as Exhibit B are OBOT’s designations of DefendantIntervenor Sierra Club’s written responses to OBOT’s Interrogatories and Requests for 

Admission, with yellow highlighting delineating the portion of those written discovery responses 

designated by OBOT. Sierra Club did not object to these designations. However, Sierra Club 

sought to “counter-designate” its own responses, and its proposed counter-designations are shown 

in green highlighting in the attached Exhibit C. OBOT objects to Sierra Club’s counterdesignations in their entirety. Sierra Club’s own written responses may not be designated or 

offered by Sierra Club at trial because they are hearsay. See Fed. R. Evid. 802. Further, certain of 

Sierra Club’s counter-designations relate to interrogatories or requests for admission that were not 

designated by OBOT in the first place, and therefore are not proper counter-designations. See 

Exhibit C, at ROG 7, RFA 5. Accordingly, OBOT respectfully requests that only those 

designations to Sierra Club’s responses attached in Exhibit B be permitted at trial. 

Dated: January 9, 2017 Respectfully submitted, 

By: /s/ Robert P. Feldman

 Robert P. Feldman 

Attorney for Plaintiff 

OAKLAND BULK & OVERSIZED 

TERMINAL, LLC

Case 3:16-cv-07014-VC Document 213 Filed 01/09/18 Page 2 of 2