Tipaksorn Tungjunyatham v. Mike Johanns

Filing 26

STIPULATION and ORDER Extending Deadline for Filing Dispositive Motions, signed by Magistrate Judge Sandra M. Snyder on 4/6/09: Dispositive Motion ddl EXTENDED from 5/20/2009 to 6/22/2009.(Hellings, J)

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LAWRENCE G.BROWN Acting United States Attorney ALYSON A. BERG Assistant United States Attorney United States Courthouse 2500 Tulare Street, Suite 4401 Fresno, California 93721 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Mike Johanns, Secretary of United States Department of Agriculture UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA TIPAKSORN TUNGJUNYATHAM, Plaintiff, v. MIKE JOHANNS, SECRETARY OF UNITED STATES DEPARTMENT OF AGRICULTURE AGENCY, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) 1:06-cv-01764-SMS STIPULATION AND ORDER EXTENDING DEADLINE FOR FILING DISPOSITIVE MOTIONS;

Plaintiff Tipaksorn Tungjunyatham ("Plaintiff") and defendant Mike Johanns, Secretary of the United States Department of Agriculture ("defendant"), stipulate to continue the dispositive motion filing deadline in this action for approximately one month as specifically set forth below. The parties base this stipulation on good cause to allow for the completion of Plaintiff's deposition prior to the filing of dispositive motions. To explain, Plaintiff began her deposition Plaintiff's deposition was

in this action on August 27, 2008.

not completed on that date and the parties agreed to continue the deposition on a mutually convenient date. However, Plaintiff

then went to Thailand to attend to the illness of a close family 1
STIPULATION AND ORDER EXTENDING DEADLINE FOR FILING DISPOSITIVE MOTIONS;

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member and did not return to the United States until March, 2009. Upon Plaintiff's return to the United States, the parties have attempted to schedule the continuation of Plaintiff's deposition, which is now set for the mutually convenient date of May 1, 2009. To allow the completion of Plaintiff's deposition and provide Plaintiff sufficient time to review the transcript, the parties have further agreed to extend the dispositive motion deadline approximately one month from May 20, 2009 to June 22, 2009. No

other dates in this action are affected by this brief extension of the dispositive motion deadline. For the reasons set forth herein, the parties therefore stipulate and agree to extend the dispositive motion filing deadline as specified below. The parties request the court

endorse this stipulation by way of formal order. Old Date Filing of Dispositive Motions Dated: April 1, 2009 Respectfully submitted, Tipaksorn Tungjunyatham
( A s authorized, 4/01/09)

New Date June 22, 2009

May 20, 2009

LAWRENCE G. BROWN Acting United States Attorney

/s/ Tipaksorn Tungjunyatham TIPAKSORN TUNGJUNYATHAM Pro Se Plaintiff IT IS SO ORDERED.

/s/ Alyson A. Berg ALYSON A.BERG Attorneys for Defendant

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STIPULATION AND ORDER EXTENDING DEADLINE FOR FILING DISPOSITIVE MOTIONS;

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 IT IS SO ORDERED. 20 21 22 23 24 25 26 27 28 Dated: icido3

CERTIFICATE OF SERVICE BY U.S. MAIL The undersigned hereby certifies that she is an employee in the Office of the United States Attorney for the Eastern District of California and is a person of such age and discretion to be competent to serve papers; That on April 1, 2009, she served a copy of: STIPULATION EXTENDING DEADLINE FOR FILING DISPOSITIVE MOTIONS; [PROPOSED] ORDER by placing said copy in a postpaid envelope addressed to the person(s) hereinafter named, at the place(s) and address(es) stated below, which is/are the last known address(es), and by depositing said envelope and its contents in the United States Mail at Fresno, California. Addressee(s): Tipaksorn Tungjunyatham 5437 W. Decatur Avenue Fresno, California 93722 /s/ Bonnie L'Argent BONNIE L'ARGENT

April 6, 2009

/s/ Sandra M. Snyder UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER EXTENDING DEADLINE FOR FILING DISPOSITIVE MOTIONS;