Mansour et al v. United States of America

Filing 14

STIPULATION and ORDER TO EXTEND NON EXPERT DISCOVERY CUT-OFF DATE TO 6/19/2009 signed by Magistrate Judge Dennis L. Beck on 4/1/2009. (Hernandez, M)

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SAGASER, JONES & HELSLEY
2445 Capitol Street, 2nd Floor Post Office Box 1632 Fresno, California 93717-1632 Telephone: [phone] Facsimile: [phone]

Michael S. Helsley #199103 Melody A. Hawkins #226522
Attorneys for:

Plaintiffs, Rashid Mansour, an individual and Two Way Fruit Stand, Inc., a California corporation UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

RASHID MANSOUR, an individual and TWO WAY FRUIT STAND, INC., a California corporation, Plaintiffs, v. UNITED STATES OF AMERICA, and DOES 1 through 20 inclusive, Defendants.

Case No. 1:08-CV-01313 LJO DLB STIPULATION TO EXTEND NONE XP E R T DISCOVERY CUT-OFF DATE AND ORDER THEREON (Rule 29 of the Federal Rules of Civil Procedure)

Plaintiffs Rashid Mansour and Two Way Fruit Stand, Inc., and Defendant, United States of America, by and through their attorneys of record hereby stipulate and agree as follows: 1. To extend the non-expert discovery cut-off date in the above-captioned

matter from May 1, 2009 to June 19, 2009. The proposed cut-off date for non-expert discovery will enable the parties to take the necessary depositions in a timely and efficient manner and complete all necessary written discovery. /// ///
{6919/002/00236081.DOC}

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STIPULATION TO EXTEND NON-EXPERT DISCOVERY COMPLETION DATE AND ORDER THEREON

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As demonstrated by the declaration of Melody A. Hawkins, counsel of record for Plaintiffs, Plaintiffs request this extension in good faith on the grounds that Plaintiffs' current financial condition has made it difficult for them to afford counsel. (Declaration of Melody A. Hawkins in Support of Extension of Non-Expert Discovery Completion Date ["Hawkins Dec."], ¶ 4) (a true copy of which is attached hereto as Exhibit "A" and incorporated herein by reference.) The additional time that has been requested will allow Plaintiffs to seek and obtain means necessary to continue and complete their non-expert discovery. (Hawkins Dec., ¶ 4). This extension will not negatively affect the furtherance of this action as it will not result in the extension of the trial date or the dates set for the filing of either non-dispositive or dispositive motions. (Hawkins Dec., ¶ 7). In Fresno, California, this 1st day of April 2009. By: _/s/ Melody A. Hawkins___________ Melody A. Hawkins Attorneys for Plaintiffs, Rashid Mansour, an individual and Two Way Fruit Stand, Inc., a California corporation

By: __/s/ Jeffrey J. Lodge_____________ Jeffrey J. Lodge Attorneys for Defendant United States of America ORDER The court having reviewed the proceeding Stipulation and good cause therefore: IT IS HEREBY ORDERED that the non-expert discovery cut-off date be extended to June 19, 2009. DATED: 1 April 2009 _____/s/ Dennis L Beck__________ Honorable Dennis L. Beck United States Magistrate Judge

{6919/002/00236081.DOC}

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STIPULATION TO EXTEND NON-EXPERT DISCOVERY COMPLETION DATE AND ORDER THEREON

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