General Security Services Corporation v. County of Fresno, California

Filing 28

STIPULATIO TO MODIFY SCHEDULING ORDER; ORDER THEREON signed by Magistrate Judge Michael J. Seng on 04/30/2012. (Yu, L)

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KEVIN B. BRIGGS
County Counsel
MICHAEL R. LINDEN
Deputy County Counsel – State Bar No. 192485
FRESNO COUNTY COUNSEL
2220 Tulare Street, 5th Floor
Fresno, California 93721
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
COUNTY OF FRESNO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION

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GENERAL SECURITY SERVICES
CORPORATION,

Case No. 1:11-CV-00724 AWI MJS
STIPULATION TO MODIFY
SCHEDULING ORDER; ORDER
THEREON.

Plaintiff,

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v.

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COUNTY OF FRESNO,
Defendant.

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Plaintiff

GENERAL

SECURITY

SERVICES

CORPORATION

(hereinafter

“Plaintiff”) and defendant COUNTY OF FRESNO (hereinafter “Defendant”) hereby
present the following Stipulation to Modify the current Scheduling Order in the abovecaptioned action.

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RECITALS
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WHEREAS, on September 29, 2011, the Court issued its initial Scheduling
Order. In said order, the cut-off date for non-expert discovery was set for June 1, 2012.

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WHEREAS, on January 13, 2012, Plaintiff served Interrogatories (Set No. 1),
Requests for Admissions (Set No. 1), and Requests for Production of Documents on
Defendant.
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Stipulation to Modify Scheduling Order

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Case No. 1:11 CV 00724 MJS

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WHEREAS, the parties have engaged in extensive meet and confer efforts

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regarding the aforementioned written discovery in order to avoid the necessity of

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intervention by the Court,

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WHEREAS, with regard to the Requests for Production of Documents, the

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parties recently agreed that Defendant would obtain and produce certain documents

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from the Probation Department’s computer systems. Said documents are identified in

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the recently signed Stipulated Protective Order, dated April 20, 2012. See Doc. No. 26.

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WHEREAS, Defendant has produced approximately half of the documents

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contemplated by the aforementioned Stipulated Protective Order. However, due to a

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previously planned vacation by Karen Rau, Staff Analyst for the Probation Department,

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the remaining documents will not be able to be identified, printed out, and produced until

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some time after May 14, 2012.

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WHEREAS, the depositions of Plaintiff’s representatives Whitney Miller and

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Steve Leopold, noticed by Defendant’s counsel for May 4, 2012, will not be able to go

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forward due to a scheduling conflict with Plaintiff’s counsel. As such, these depositions

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will not be able to be taken until the last week in May, 2012.
WHEREAS, no previous modification of the Scheduling Order has taken place.

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STIPULATION

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Now, therefore, IT IS HEREBY STIPULATED AND AGREED, by and between

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the parties, through their respective attorneys of record that:
1.

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July 6, 2012.
2.

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The non-expert discovery cut-off date be extended from June 1, 2012 to

The expert discovery cut-off date, and the last day to file a non-dispositive

motion, be extended from August 1, 2012 to August 22, 2012.
3.

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same.

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///

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All other operative dates in the existing Scheduling Order will remain the

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Stipulation to Modify Scheduling Order

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Case No. 1:11 CV 00724 MJS

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IT IS SO STIPULATED.

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Dated: April 27, 2012

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KEVIN B. BRIGGS
County Counsel

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By:

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/s/ Michael Linden
Michael R. Linden, Deputy
Attorneys for Defendant

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Dated: April 27, 2012

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VAUGHN LEGAL GROUP

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By:

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/s/ Kelly Everett
Kelly Everett
Attorney for Plaintiff

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ORDER

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DEAC_Signature-END:

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ci4d6

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IT IS SO ORDERED.
Dated:

April 30, 2012

/s/

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Michael J. Seng

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

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Stipulation to Modify Scheduling Order

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Case No. 1:11 CV 00724 MJS