Sandres v. Corrections Corporation of America

Filing 77

STIPULATION and ORDER re 76 to Extend Filing Deadline and Hearing Date for Motions to Compel signed by Magistrate Judge Jennifer L. Thurston on 4/13/2011. Filing Deadline: 4/29/2011, Case Management Deadline: 6/10/2011.(Leon-Guerrero, A)

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Barry M. Appell, Esq. State Bar No.: 174324
APPELL HILAIRE BERNARDO LLP
15233 Ventura Blvd., Suite 420
Sherman Oaks, CA 91403
[phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Plaintiff,
Terry Sandres

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PAUL M. GLEASON State Bar No.: 155569
RICHARD Y. CHEN State Bar No.: 225392
KATHY H. GAO State Bar No.: 259019
GLEASON & FAVAROTE, LLP
800 West Sixth Street, Suite 1010
Los Angeles, California 90017
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
Corrections Corporation of America and
CCA of Tennessee, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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TERRY SANDRES, an individual,

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Plaintiff,
vs.

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CORRECTIONS CORPORATION OF
AMERICA, a Maryland corporation; and
Does 1 through 50, inclusive,
Defendants.

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Case No. 1:09-cv-01609-OWW-JLT
STIPULATION AND ORDER TO EXTEND
THE FILING DEADLINE AND HEARING
DATE FOR MOTIONS TO COMPEL ON
CERTAIN DISCOVERY DISPUTES
Magistrate
Judge:
Action Filed:
Trial Date:

Hon. Jennifer L. Thurston
July 24, 2009
August 30, 2011

THE PARTIES TO THE ABOVE-CAPTIONED MATTER, by and through their
respective attorneys of record, hereby enter into this stipulation to extend the deadline and hearing
date for motions to compel on certain discovery disputes detailed below based on the following:
WHEREAS, the deadline to file non-dispositive pre-trial motions is April 15, 2011
(Declaration of Kathy H. Gao (“Gao Decl.”), ¶ 2); and

WHEREAS, at issue now are written discovery requests defendants Corrections
Corporation of America (“Corrections Corp.”) and CCA of Tennessee, LLC (“CCA”) (hereinafter
collectively referred to as “Defendants”) served on plaintiff Terry Sandres (“Plaintiff”) which
include the following:
(a)

CCA’s Third Set of Requests for Production of Documents (Nos. 50-51);

(b)

CCA’s Second Set of Requests for Admissions (Nos. 6-7);

(c)

CCA’s Second Set of Special Interrogatories (Nos. 17-19);

(d)

CCA’s Third Set of Special Interrogatories (No. 20);

(e)

Corrections Corp.’s Second Set of Special Interrogatories (Nos. 17-24);

(hereinafter collectively referred to as the “Discovery Requests”) (Gao Decl., ¶ 3); and
WHEREAS, Plaintiff has served responses to the Discovery Requests (Gao Decl., ¶ 4); and
WHEREAS, on March 25, 2011, Defendants’ counsel sent Plaintiff’s counsel a meet and
confer letter regarding Plaintiff’s responses to the Discovery Requests and called for Plaintiff to
provide supplemental responses thereto no later than April 1, 2011 (Gao Decl., ¶ 5); and
WHEREAS, on March 31, 2011, Plaintiff’s counsel responded to Defendants’ counsel’s
March 25, 2011 meet and confer letter and indicated that Plaintiff would not be able to provide
supplemental discovery responses until the week of April 11, 2011, at the earliest, due to a prepaid
vacation from April 2-9, 2011 (Gao Decl., ¶ 6); and
WHEREAS, the parties have scheduled private mediation for April 14, 2011 (Gao Decl.,
¶ 7); and

WHEREAS, the parties have continued to diligently meet and confer on these outstanding
discovery disputes (Gao Decl., ¶ 8); and
WHEREAS, to allow the parties additional time to meet and confer on the pending

discovery issues and participate in private mediation, as well as to avoid burdening the court with
unnecessary discovery motions, the parties believe that it is in their best interest, as well as in the
preservation of their financial resources, that the deadline to file any necessary motions to compel
concerning the Discovery Requests – limited to the issues specifically identified in Defendants’
March 25, 2011 meet and confer correspondence – be continued to April 29, 2011, and the date to
have such motions heard by the Court be continued to June 10, 2011 (Gao Decl., ¶ 9).
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED and requested by
the parties through their respective attorneys of record that this Court order as follows:
1.

That the deadline to file any necessary motions to compel concerning the Discovery
Requests – limited to the issues specifically identified in Defendants’ March 25,
2011 meet and confer correspondence – is continued to April 29, 2011; and

2.

That the date to have any necessary motions to compel concerning the Discovery
Requests – limited to the issues specifically identified in Defendants’ March 25,
2011 meet and confer correspondence – heard by the Court is continued to June 10,
2011.

IT IS SO STIPULATED.
APPELL HILAIRE BERNARDO LLP
/s/ Barry M. Appell
(As authorized on 4/13/11)
By: ___________________________
Barry M. Appell
Attorneys for Plaintiff Terry Sandres
Dated: April 13, 2011

GLEASON & FAVOROTE LLP
/s/ Kathy H. Gao
By: __________________________
Kathy H. Gao
Attorneys for Defendants Corrections Corporation
of America and CCA of Tennessee, LLC

IT IS SO ORDERED.
Dated:

April 13, 2011

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

DEAC_Signature-END:

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