Tumbling v. Merced Irrigation District

Filing 85

STIPULATION and ORDER to extend the completion date for the taking of the non-expert deposition of Trudy Largent by 30 days. Order signed by Magistrate Judge Dennis L. Beck on 4/13/2010. (Hernandez, M)

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Lawrence D. Murray (SBN 77536) MURRAY & ASSOCIATES 1781 Union Street San Francisco, CA 94123 Tel: [phone] Fax: [phone] Dean Gordon (SBN 61311) LAW OFFICES OF DEAN GORDON 1220 East Olive Avenue Fresno, CA 93728 Tel: [phone] Fax: [phone] ATTORNEYS FOR PLAINTIFF LAMONTE TUMBLING DALEY & HEFT, ATTORNEYS AT LAW Neal S. Meyers, Esq.(SBN 109625) Matthew T. Racine, Esq. (SBN 256865) 462 Stevens Avenue, Suite 201 Solana Beach, CA 92075 Tel: [phone] Fax: [phone] ATTORNEYS FOR DEFENDANT, MERCED IRRIGATION DISTRICT UNITED STATES DISTRICT COURT Eastern District of California Fresno Division LaMonte Tumbling, Plaintiff, vs. Merced Irrigation District, a public entity, Defendant. No. 1:08-CV-01801 LJO DLB JOINT STIPULATION FOR EXTENSION OF LITIGATION DEADLINES AND SCHEDULING ORDER

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Tumbling vs. Merced Irrigation District Page 1 United States District Court, Eastern District of California, Fresno Division, Case No. 1:08-CV-01801 LJO DLB
JOINT STIPULATION AND [PROPOSED] SCHEDULING ORDER

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LaMonte Tumbling ("Plaintiff") and Merced Irrigation District ("Defendant"), by and through their respective attorneys of record, hereby stipulate to and request the Court enter a scheduling order revising the amended scheduling order entered by this court on February 12, 2010. (See Joint Stipulation and Order attached as Exhibit A). The revisions to the scheduling order are as follows: (a) Extend the completion date for the taking of the non-expert deposition of Trudy Largent by 30 days from April 15, 2010, to May, 14, 2010. Good cause exists to extend the deposition discovery deadline for Trudy Largent by 30 days in light of: (a) Ms. Trudy Largent is not available for deposition on the date noticed by Plaintiffs on April 5, 2010 and will not be available until after the completion date of April 15, 2010. For these reasons, the parties respectfully request the Court modify the Pre Trial Scheduling Order so that it conforms to the foregoing new discovery cut-off date for the deposition of Trudy Largent. Date: __March 30, 2010

MURRAY & ASSOCIATES /s/ Lawrence D. Murray Lawrence D. Murray Attorney for Plaintiff

DALEY & HEFT /s/ Matthew T. Racine Matthew T. Racine Attorney for Defendant

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Tumbling vs. Merced Irrigation District Page 2 United States District Court, Eastern District of California, Fresno Division, Case No. 1:08-CV-01801 LJO DLB
JOINT STIPULATION AND [PROPOSED] SCHEDULING ORDER

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DEAC_Signature-END:

ORDER ON STIPULATION FOR ORDER HAVING READ AND CONSIDERED THE FOREGOING, and good cause appearing: The foregoing is the order of the court.

IT IS SO ORDERED. Dated:

April 13, 2010

/s/ Dennis

L. Beck

UNITED STATES MAGISTRATE JUDGE 3b142a

Tumbling vs. Merced Irrigation District Page 3 United States District Court, Eastern District of California, Fresno Division, Case No. 1:08-CV-01801 LJO DLB
JOINT STIPULATION AND [PROPOSED] SCHEDULING ORDER