Log Cabin Republicans v. United States of America et al

Filing 122

Joint STIPULATION for Leave to Take Depositions Outside of the Discovery Period filed by Defendants Donald H Rumsfeld, United States of America. (Attachments: #1 Proposed Order)(Parker, Ryan)

Log Cabin Republicans v. United States of America et al

Doc. 122

1 TONY WEST Assistant Attorney General 2 ANDRE BIROTTE, Jr. 3 United States Attorney 4 VINCENT M. GARVEY Deputy Branch Director 5 PAUL G. FREEBORNE 6 W. SCOTT SIMPSON RYAN B. PARKER 7 U.S. Department of Justice Civil Division 8 Federal Programs Branch Post Office Box 883 9 Washington, D.C. 20044 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] 11 Attorneys for Defendants United States 12 of America and Secretary of Defense 13 14 16 17 v. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA EASTERN DIVISION Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CV04-8425 VAP (Ex) STIPULATION TO TAKE DEPOSITIONS OUTSIDE OF DISCOVERY PERIOD

15 LOG CABIN REPUBLICANS,

18 UNITED STATES OF AMERICA AND ROBERT GATES, Secretary of Defense, 19 Defendants. 20 21 22 23 24 25 26 27 28

WHEREAS, the Court has set a discovery deadline of March 15, 2010. WHEREAS, Plaintiff's experts Alan Okros and Melissa Sheridan EmbserHerbert currently reside in Canada, and Defense counsel need additional time to received clearance from the Canadian Government to take depositions on Canadian soil.
UNITED STATES DEPARTMENT OF JUSTICE CIVIL DIVISION, FEDERAL PROGRAMS BRANCH P.O. BOX 883, BEN FRANKLIN STATION WASHINGTON, D.C. 20044 [phone]

STIPULATION TO TAKE DEPOSITIONS OUTSIDE OF DISCOVERY PERIOD

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WHEREAS, Plaintiff's expert Lawrence Korb has medical issues that will WHEREAS, under Federal Rule of Civil Procedure 29, parties may stipulate IT IS HEREBY STIPULATED AND AGREED THAT: Defendants will take the depositions of Plaintiff's experts Alan Okros,

2 prevent him from being deposed before the discovery deadline. 4 to take depositions outside of the discovery period with court approval.

7 Melissa Sheridan Embser-Herbert and Lawrence Korb outside of the discovery 8 period. It is anticipated that Alan Okros will be deposed on March 26, Melissa 9 Embser-Herbert will be deposed on March 29, and Lawrence Korb will be deposed 10 on April 2. All depositions must be complete by April 15, 2010. 11 12 /s/ Ryan B. Parker Ryan B. Parker 13 U.S. Department of Justice Civil Division 14 Federal Programs Branch P.O. Box 883 15 Washington, D.C. 20044 Telephone: [phone] Facsimile: [phone] Attorney for Defendants 17 Dated: March 10, 2010 18 _ 19 20 21 22 23 24 25 26 27 28
STIPULATION TO TAKE DEPOSITIONS OUTSIDE OF DISCOVERY PERIOD UNITED STATES DEPARTMENT OF JUSTICE CIVIL DIVISION, FEDERAL PROGRAMS BRANCH P.O. BOX 883, BEN FRANKLIN STATION WASHINGTON, D.C. 20044 [phone]

/s/ Patrick Hunnius Patrick Hunnius White & Case, LLP 633 West Fifth Street Suite 1900 Los Angeles, CA 90071 Telephone: [phone] Facsimile: [phone] Attorney for Plaintiff

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