Blue Lake Rancheria, et al v. Morgenstern, et al.,

Filing 74

STIPULATION and ORDER signed by Judge John A. Mendez on 11/3/14: The deadline for the parties to file and serve joint status report and joint discovery plan is December 12, 2014. (Kaminski, H)

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BOUTIN JONES INC.
Robert R. Rubin, SBN 117428
Michael E. Chase, SBN 214506
555 Capitol Mall, Suite 1500
Sacramento, CA 95814-4603
Tel.: [phone]
Fax: [phone]
RAPPORT AND MARSTON
David J. Rapport, SBN 054384
405 West Perkins Street
P.O. Box 488
Ukiah, CA 95482
[phone]

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Attorneys for plaintiffs Blue Lake Rancheria, Blue Lake Rancheria Economic
Development Corp. and Mainstay Business Solutions

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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BLUE LAKE RANCHERIA, a federally
recognized Indian Tribe, et al.,

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Plaintiffs,

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STIPULATION AND ORDER REGARDING
DEADLINE FOR FILING JOINT STATUS
REPORT AND DISCOVERY PLAN

vs.

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CASE NO. 2:11-cv-01124-JAM-JFM

MARTY MORGENSTERN, individually and
in his capacity as Secretary of the California
Labor and Workforce Development Agency,
et al.,

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Defendants.

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UNITED STATES,
Intervenor.

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Plaintiffs Blue Lake Rancheria, Blue Lake Rancheria Economic Development Corporation,

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and Mainstay Business Solutions; defendants Marty Morgenstern, Pam Harris, Jack Budmark,

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Talbott Smith, Kathy Dunne, and Sarah Reece; and intervenor United States, collectively, “the

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parties,” stipulate as follows:

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STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINE FOR FILING JOINT STATUS
REPORT AND DISCOVERY PLAN
647881.1

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The Complaint was filed on April 26, 2011.

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On July 11, 2011, upon stipulation between plaintiffs and defendants, this Court

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ordered that the time for the parties to file and serve (1) the parties’ joint status report, (2) the

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parties’ joint discovery plan and (3) the parties’ initial disclosures pursuant to Federal Rules of

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Civil Procedure, Rules 16(b) and 26(f)(3), is extended pending further order of the Court.

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3.

On December 22, 2011, defendants filed an Answer to the Complaint.

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4.

On October 2, 2012, intervenor filed an Answer and Claim.

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5.

On October 23, 2012, plaintiffs filed an Answer to intervenor’s Claim.

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6.

All parties agree that this Court should re-set the deadline for the parties to file and

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serve their joint status report and joint discovery plan, and request that the Court set such deadline

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for December 12, 2014.

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Dated: November 3, 2014.

BOUTIN JONES INC.

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By:

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Dated: November 3, 2014.

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KAMALA D. HARRIS
Attorney General of California
By:

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Dated: November 3, 2014.

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/s/ Michael E. Chase
Michael E. Chase
Attorneys for plaintiffs

/s/ Jill Bowers
Jill Bowers
Attorneys for defendants

KATHRYN KENEALLY
Assistant Attorney General
By:

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/s/ W. Carl Hankla
W. Carl Hankla
Michael E. Chase
Attorneys for intervenor

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STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINE FOR FILING JOINT STATUS
REPORT AND DISCOVERY PLAN
647881.1

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ORDER
Based upon the stipulation of the parties, and for good cause shown, the Court hereby

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ORDERS that the deadline for the parties to file and serve (1) the parties’ joint status report and

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(2) the parties’ joint discovery plan is December 12, 2014.

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Dated: _11/3/2014
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/s/ John A. Mendez_______________
______________________
Hon. John A. Mendez
Judge
United States District Court

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STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINE FOR FILING JOINT STATUS
REPORT AND DISCOVERY PLAN
647881.1