Lum v. County of San Joaquin, et al.,

Filing 57

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 12/14/11 ORDERING that each side may conduct up to 20 depositions. (Benson, A.)

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DANA A. SUNTAG (State Bar #125127)
JOSHUA J. STEVENS (State Bar # 238105)
ZOEY P. MERRILL (State Bar #268331)
THE SUNTAG LAW FIRM
A PROFESSIONAL CORPORATION
The Kress Building
20 North Sutter Street, Fourth Floor
Stockton, California 95202
Telephone: [phone]
Facsimile: [phone]
MATTHEW P. DACEY (State Bar #196943)
OFFICE OF THE COUNTY COUNSEL OF SAN JOAQUIN
Deputy County Counsel
44 North San Joaquin Street, Suite 679
Stockton, California 95202
Telephone: [phone]
Attorneys for All Defendants

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JERRY LUM, etc., et al.,

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Plaintiffs,

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v.

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COUNTY OF SAN JOAQUIN, et al.,
Defendants.

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STIPULATION AND PROPOSED ORDER
INCREASING NUMBER OF DEPOSITIONS

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NO. 2:10-CV-01807-LKK-DAD
STIPULATION AND ORDER
INCREASING THE NUMBER OF
DEPOSITIONS THE PARTIES
MAY CONDUCT
[F.R.C.P. 30(a)(2)]

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This stipulation and proposed order is entered into between Plaintiffs

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Jerry Lum and Dorothea Timmons (collectively “Plaintiffs”), on the one hand, and

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Defendants County of San Joaquin, City of Lathrop, Ray Walters, Steven Pease,

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Robert Davis, and Felipe Mendoza (collectively “Defendants”), on the other hand.
RECITALS

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A.

Each side requires additional depositions beyond the

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10 depositions allowed by FRCP 30(a) to complete its necessary discovery and

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effectively prepare for trial.

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B.

Plaintiffs have conducted nine depositions and have noticed the

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depositions of six of defendants’ expert witnesses. In addition, Defendants disclosed

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four non-retained experts, and Plaintiffs may wish to conduct their depositions.

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C.

Defendants have conducted six depositions and have noticed the

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depositions of two additional percipient witnesses. In addition, Plaintiffs have disclosed

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four expert witnesses and four non-retained experts. It is anticipated that Defendants

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may need to conduct their depositions and Defendants may wish to conduct other

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percipient depositions.

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D.

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20 depositions.

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E.

The parties have agreed that each side may conduct up to

The parties intend to complete all depositions by the discovery cut-

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off date of January 31, 2012, and are not requesting an extension of the discovery cut-

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off date.

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STIPULATION AND PROPOSED ORDER
INCREASING NUMBER OF DEPOSITIONS

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STIPULATION
IT IS STIPULATED AND AGREED, by the parties, through their counsel

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of record, that each side may conduct up to 20 depositions.

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Dated: December 14, 2011

THE SUNTAG LAW FIRM
A Professional Corporation

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By: __/s/ Dana A. Suntag____________
DANA A. SUNTAG
Attorneys for All Defendants

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Dated: December 14, 2011

WALKER, HAMILTON & KOENIG LLP

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By: __/s/ Peter J. Koenig____________
PETER J. KOENIG
Attorneys for All Plaintiffs

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ORDER

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It is so ordered.
Dated: December 14, 2011

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DDAD1\orders.civil\lum1807.stip.depos.ord.doc

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STIPULATION AND PROPOSED ORDER
INCREASING NUMBER OF DEPOSITIONS

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