Zamora v. Department of Homeland Security et al

Filing 137

STIPULATION and ORDER signed by Judge John A. Mendez on 02/28/11 ORDERING that the Court MODIFIES the (#94) 01/06/11 Minute Order as follows: Discovery cut-off 05/18/11; last day to file Dispositive motions is 06/22/11; hearing on dispositive motions is 07/20/11 at 9:30 a.m.; Joint pretrial statement due 09/02/11; Final Pretrial Conference set for 09/09/11 at 10:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez and Jury Trial set for 10/17/11 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Benson, A.)

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Mark E. Ellis - 127159 Ronald R. Poirier - 175511 Teresa L. Zuber - 164213 ELLIS, LAVOIE, POIRIER, STEINHEIMER & McGEE LLP 555 University Avenue, Suite 200 East Sacramento, CA 95825 Tel: [phone] Fax: [phone] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff JENNIFER ZAMORA

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND ORDER Plaintiff Jennifer Zamora and Defendant, Janet Napolitano, Secretary of The Department of Homeland Security hereby stipulate and agree that good cause exists for an extending discovery cut-off and continuing the trial date. On Wednesday, February 23, 2011, counsel for both parties appeared before the Hon. Magistrate Judge Edmund F. Brennan regarding Plaintiff's motion to compel further discovery. On February 24, 2011, Judge Brennan issued an order granting in part and denying in part Plaintiff's motion. See Docket No. 135 re: Order. In addition to addressing Plaintiff's written discovery requests, -1______________________________________________________________________________________________________________________________________________________________________________________________________________________

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

JENNIFER ZAMORA, Plaintiff, v. JANET NAPOLITANO, SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY; GALE ROSSIDES, ASSISTANT SECRETARY/ACTING ADMINISTRATOR OF THE TRANSPORTATION SECURITY ADMINISTRATION; LOREN ISHII; and DOES 1-20, Defendants.

Case No.: 2:09-CV-1292-JAM-EFB STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF DATE AND CONTINUE TRIAL DATE TRIAL DATE: August 8, 2011

STIPULATION AND [PROPOSED] ORDER EXTENDING DISCOVERY CUT-OFF AND TRIAL DATES

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Judge Brennan granted Plaintiff's request to take 3 new additional depositions and re-open another deposition. The total number of depositions remaining to be taken and/or completed is now 8. The parties, along with Judge Brennan, agreed an additional 60 days may be needed to complete additional discovery ordered by Judge Brennan. Judge Brennan opined that most likely the trial date would have to be continued to accommodate the court and directed Plaintiff's counsel to contact Mr. Vine, clerk for Judge Mendez who is assigned to preside over this case. Mr. Vine provided the following new dates which are agreeable to counsel: Discovery cut-off Dispositive motion filing: Dispositive motion hearing: 5/18/2011 6/22/11 7/20/11 @ 9:30 a.m. 9/2/11 9/9/11 @ 10 a.m. 10/17/11 @ 9:00 a.m. Respectfully submitted by: ELLIS, LAVOIE, POIRIER, STEINHEIMER, & MCGEE LLP Dated: February 28, 2011 By /s/ Ronald R. Poirier________________ Ronald R. Poirier Attorneys for Plaintiff JENNIFER ZAMORA

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Joint pretrial statement filed: Final pretrial conference: Jury trial:

Benjamin B. Wagner United States Attorney Dated: February 28, 2011 By /s/ Jason Ehrlinspiel__________________

Jason Ehrlinspiel Assistant United States Attorney, Attorney for DEFENDANT JANET NAPOLITANO, SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY

STIPULATION AND [PROPOSED] ORDER EXTENDING DISCOVERY CUT-OFF AND TRIAL DATES

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ORDER Good cause has been shown to continue the discovery cut-off date in this case. Accordingly, the Court modifies its order of January 6, 2011 as follows: The trial date of August 8, 2011 is vacated. Discovery cut-off date is May 18, 2011. Last day to file Dispositive motions, June 22, 2011. Hearing on dispositive motions, July 20, 2011 at 9:30 a.m. Joint pretrial statement due September 2, 2011. Final pretrial conference on September 9, 2011 at 10:00 a.m. Jury trial, October 17, 2011 at 9:00 a.m. SO ORDERED. DATED: 2/28/2011 /s/ John A. Mendez_________________ JOHN A. MENDEZ UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER EXTENDING DISCOVERY CUT-OFF AND TRIAL DATES

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