Eaglesmith et al v. Ray et al

Filing 105

STIPULATION and ORDER re deposition of Jim Lake signed by Judge John A. Mendez on 6/1/12. (Kaminski, H)

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DAN SIEGEL, SBN 56400
PETER HABERFELD, SBN 41723
SIEGEL & YEE
499 14th Street, Suite 220
Oakland, CA 94612
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
JERALD CLINTON (J.C.) EAGLESMITH,
RAMONA EAGLESMITH,
EILEEN COX, and BRUCE BARNES

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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JERALD CLINTON (J.C.) EAGLESMITH, ) Case No. 2:11-CV-00098-JAM-JFM
RAMONA EAGLESMITH, EILEEN COX, )
and BRUCE BARNES,
) STIPULATION AND ORDER TO TAKE
) THE DEPOSITION
Plaintiffs,
) ON JIM LAKE ON JUNE 7, OR JUNE 11,
vs.
) 2012
)
JEFF RAY, as an individual, SUE
)
SEGURA, as an individual, and BOARD )
OF TRUSTEES OF PLUMAS COUNTY
)
OFFICE OF EDUCATION/ PLUMAS
)
COUNTY UNIFIED SCHOOL DISTRICT, )
)
Defendants.
)
Plaintiffs J.C. Eaglesmith, Ramona Eaglesmith, Bruce Barnes and Eilleen Cox,
and defendants Plumas County Office of Education/Plumas Unified School District, Sue
Segura, and Jeff Ray, by and through their attorneys of record, hereby stipulate as
follows:

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1. On May 22, 2012, the Court issued an Order (Dkt. No. 103) allowing plaintiffs

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to take the deposition of Jim Lake, Principal at Greenville Junior/Senior High

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School in Plumas County Unified School District, and that they be allowed to
take his deposition in lieu of the deposition of Brad Baker. The parties had
Eaglesmith v. Ray, Case No. 2:11-cv-00098-JAM-JFM
Stipulation and Order to Depose Jim Lake on June 7 or June 11, 2012 - 1

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scheduled the deposition of Mr. Baker for Thursday, May 31, 2012 in

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Sacramento, California at 1:00 PM.

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2. On Tuesday, May 29, 2012, defendants’ counsel communicated to plaintiffs’

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counsel Mr. Lake’s proposal that, for his convenience, his deposition be

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scheduled to either June 7 at 1:00 PM or June 11 at 10:00 AM or later in
Sacramento. On May 30, 2012, defendants’ counsel wrote to plaintiffs’
counsel that Mr. Lake is unavailable on May 31, 2012.
3. The Court’s Status (Pre-trial Scheduling) Order (Dkt. No. 19) states “all
discovery shall be completed by June 1, 2012. In this context, ‘completed’
means that all discovery shall have been conducted so that all depositions
have been taken ….”
4. The parties agree to schedule the deposition of Mr. Lake on either of the two
dates proposed by Mr. Lake.
5. The parties agree to waive the discovery cut-off as it pertains only to this

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deposition for the purpose of the convenience of Mr. Lake. The cut-off would

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be waived for no other purpose.

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Dated: May 30, 2012

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SIEGEL & YEE

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By: /s/Peter Haberfeld
Peter Haberfeld

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Attorneys for Plaintiffs

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Dated: May 30, 2012

STUBBS & LEONE
By: /s/ Brian Duus
Brian Duus
Attorneys for Defendants

Eaglesmith v. Ray, Case No. 2:11-cv-00098-JAM-JFM
Stipulation and Order to Depose Jim Lake on June 7 or June 11, 2012 - 2
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IT IS SO ORDERED

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Dated: June 1, 2012
/s/ John A. Mendez__________
U. S. District Court Judge

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Eaglesmith v. Ray, Case No. 2:11-cv-00098-JAM-JFM
Stipulation and Order to Depose Jim Lake on June 7 or June 11, 2012 - 3
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