General Security Services Corporation v. County of Fresno, California

Filing 31

STIPULATION and ORDER GRANTING the parties' request to modify the scheduling order as follows: Non-Expert Discovery to be filed by 10/9/2012; Expert Discovery and Non-Dispositive Motions to be filed by 11/30/2012; Designation of Expert Witnesses to be filed by 11/1/2012; Dispositive Motions to be filed by 12/14/2012; Pretrial Conference set for 3/4/2013 at 09:30 AM in Courtroom 6 (MJS) before Magistrate Judge Michael J. Seng; Jury Trial set for 4/1/2013 at 09:00 AM in Courtroom 6 (MJS) before Magistrate Judge Michael J. Seng; order signed by Magistrate Judge Michael J. Seng on 6/14/2012. (Rooney, M)

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BARAK VAUGHN (SBN 227926)
VAUGHN LEGAL GROUP
23622 Calabasas Rd., Suite 220
Calabasas, California 91302
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff,
GENERAL SECURITY SERVICES CORPORATION
KEVIN BRIGGS
County Counsel
MICHAEL R. LINDEN (SBN 192485)
Deputy County Counsel
FRESNO COUNTY COUNSEL
2220 Tulare Street, 5th Floor
Fresno, California 93721
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,

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Plaintiff,

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STIPULATION TO MODIFY
SCHEDULING ORDER; ORDER
THEREON

vs.

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Case No. 1:11-cv-00724 AWI MJS

COUNTY OF FRESNO,

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Defendant.

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Plaintiff, GENERAL SECURITY SERVICES CORPORATION (hereinafter

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“GSSC”), by and through its attorney Barak Vaughn, Esq. of the Vaughn Legal

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Group and Defendant, COUNTY OF FRESNO (hereinafter “County”), by and

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through its attorney of record, Michael R. Linden, of the Fresno County Counsel,

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do and hereby present the following Stipulation to Agree to Modify the current
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Stipulation Modify Scheduling Order

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Scheduling Order in the above-captioned action.

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RECITALS
WHEREAS, on September 29, 2011, the Court issued its initial Scheduling
Order cutting off non-expert discovery on June 1, 2012.
WHEREAS, on January 13, 2012, Plaintiff propounded on Defendant
Plaintiff’s Interrogatories (Set One), Requests for Admissions (Set One), and
Requests for Identification of Documents (Set One).
WHEREAS, the parties engaged in extensive meet and confer efforts
regarding he aforementioned discovery.
WHEREAS, the parties stipulated and the Honorable Michael Seng ordered
this Court’s previous Scheduling Order be modified to extend the non-expert
discovery cut-off date from June 1, 2012 to July 6, 2012, and to extend the expert
discovery cut-off date and the last day to file a non-dispositive motion, from August
1, 2012 to August 22, 2012. This Order was filed on May 1, 2012.
WHEREAS, the parties participated in a discovery dispute hearing on May
23, 2012. During the hearing, the parties agreed to extend both expert and nonexpert discovery cut off dates, should it be necessary.
WHEREAS, the parties have met, conferred, and determined non-expert
discovery and non-expert discovery cut-off dates must be extended at least ninety
(90) days; and that all other operative dates in this Court’s existing Scheduling
Order too must be extended at least ninety (90) days.

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STIPULATION
For good cause showing, IT IS HEREBY STIPULATED AND AGREED, by
and between the parties, through their respective attorneys of record, that:
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The non-expert discovery cut-off date is extended from July 6, 2012 to

October 8, 2012.
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The expert discovery cut-off date, and the last day to file a non-

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Stipulation Modify Scheduling Order

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dispositive motion is extended from August 22, 2012 to November 30, 2012.
3.

The deadline for the disclosure of expert witnesses is extended from

August 1, 2012 to November 1, 2012.
4.

The deadline to file a dispositive motion is extended from September

7, 2012 to December 14, 2012.
5.

The pre-trial conference date is extended from December 4, 2012 to

March 4, 2013.
6.

The trial date is extended from January 29, 2013 to April 1, 2013.

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IT IS SO STIPULATED.

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Dated: June 14, 2012

VAUGHN LEGAL GROUP

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/s/ Barak Vaughn
_____________________________
Barak Vaughn, Esq.
Attorneys for Plaintiff,
GENERAL SECURITY SERVICES
CORPORATION

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Dated: June 5, 2012

FRESNO COUNTY COUNSEL

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/s/ Michael Linden
______________________________
Kevin Briggs
County Counsel
Michael R. Linden
Deputy County Counsel
Attorneys for Defendant,
COUNTY OF FRESNO

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ORDER
GOOD CAUSE APPEARING, the above Stipulation is approved,

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Stipulation Modify Scheduling Order

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and the Scheduling Order shall be modified to reflect the new stipulated dates set

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forth above.

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IT IS SO ORDERED.

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Dated:

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June 14, 2012

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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DEAC_Signature-END:

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Stipulation Modify Scheduling Order