Solis v. National Emergency Medical Services Association

Filing 68

STIPULATION and ORDER Extending Non-Expert Discovery Deadline signed by Magistrate Judge Gary S. Austin on 3/21/2012. IT IS HEREBY ORDERED that the non-expert discovery deadline be moved from April 2, 2012, to May 23, 2012. All other dates and deadlines set forth in the Court's Scheduling Order remain in effect.(Bradley, A)

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BENJAMIN B. WAGNER
United States Attorney
GLEN F. DORGAN
Assistant United States Attorney
United States Courthouse
2500 Tulare Street, Suite 4401
Fresno, California 93721
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff, HILDA L. SOLIS, Secretary of Labor,
United States Department of Labor

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IN THE UNITED STATES DISTRICT COURT FOR THE

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EASTERN DISTRICT OF CALIFORNIA

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HILDA L. SOLIS, Secretary of Labor,
United States Department of Labor,

) Case No. 1:11-cv-00529 AWI-GSA
)
) STIPULATION AND ORDER
Plaintiff,
) EXTENDING NON-EXPERT DISCOVERY
v.
) DEADLINE
)
NATIONAL EMERGENCY MEDICAL )
SERVICES ASSOCIATION,
)
)
Defendant.
)
___________________________________ )

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Plaintiff, Hilda L. Solis, Secretary of Labor, United States Department of Labor, and

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Defendant, National Emergency Medical Services Association, through its counsel of record,

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respectfully request a continuance of the expert discovery deadline due to the following:

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1. At present, the non-expert discovery cut-off is April 2, 2012. However, due to
scheduling conflicts involving two of Plaintiff’s principle witnesses (Vivian Thorbourne and

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David Pinck) and one of Defendant’s principle witnesses (Torren Colcord), the parties have

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been unable to complete these depositions to date. The depositions of Mr. Pinck and Ms.

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Thorbourne are set for March 29 and 30, 2012, and a date has yet to be confirmed for the
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___________________________________________________________________________________
STIPULATION AND ORDER EXTENDING NON-EXPERT DISCOVERY DEADLINE

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deposition of Mr. Colcord. Moreover, once these depositions are completed, the information
secured at these proceedings may justify depositions of additional witnesses.

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2. The expert discovery cut-off is May 23, 2012. The parties desire, and hereby

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stipulate, to continue the non-expert discovery deadline to conclude concurrently with the expert

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discovery cut-off so that the other dates identified in the Court’s Scheduling Order will remain

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unaffected.

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Dated: March 21, 2012

BENJAMIN B. WAGNER
United States Attorney

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By

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/s/ Glen F.Dorgan
Glen F. Dorgan
Assistant United States Attorney
Attorney for Plaintiff,
HILDA L. SOLIS, Secretary of Labor,
United States Department of Labor

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Dated: March 21, 2012

GOYETTE & ASSOCIATES, INC.
/s/ Paul Goyette
Paul Goyette
Attorney for Defendant
National Emergency Medical Services Association

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ORDER

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IT IS HEREBY ORDERED that the non-expert discovery deadline be moved from April

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2, 2012, to May 23, 2012. All other dates and deadlines set forth in the Court’s Scheduling

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Order remain in effect.

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IT IS SO ORDERED.
Dated:
6i0kij

March 21, 2012

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER EXTENDING NON-EXPERT DISCOVERY DEADLINE