Davis v. Jackson Laboratory

Filing 12

STIPULATION and ORDER signed by Judge Morrison C. England, Jr. on 8/23/2012 ORDERING that, pursuant to the parties' Stipulation, discovery motions and Plaintiff's deposition related to any alcohol-related line of questioning will not be sub ject to the 9/21/2012 discovery cut-off. As to the alcohol-related issue only, the discovery deadline will remain open until the court rules on whether the alcohol-related questions are permitted at Plaintiffs deposition, and Plaintiff's deposition has concluded as to that issue only (if the court permits any questioning). All other discovery must be completed by the 9/21/2012 discovery cut-off. (Zignago, K.)

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SHAW VALENZA LLP
D. Gregory Valenza, Bar No. 161250
[e-mail]
Amy K. Lee, Bar No. 244542
[e-mail]
300 Montgomery Street, Suite 788
San Francisco, California 94104
Telephone: [phone]
Facsimile: (415) 983-596
Attorneys for Defendant
The Jackson Laboratory
Leo F. Donahue, Esq.
Leo F. Donahue, Inc.
[e-mail]
11344 Coloma Road, Suite 160
Gold River, CA 95670
Tele: [phone]
Fax: [phone]
Attorneys for Plaintiff Kelly Keehner

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO DIVISION

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KRISTINA Y. DAVIS,

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Plaintiff,
v.

STIPULATION AND ORDER TO PERMIT
LIMITED DISCOVERY BEYOND
DISCOVERY DEADLINE
[E.D. Cal. L. R. 137; 143]

THE JACKSON LABORATORY, a
Corporation of unknown origin; and DOES
1 through 100, inclusive,

Judge:

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Case No. 2:11-cv-01944-MCE-DAD

Hon. Dale A. Drozd
U.S. Magistrate Judge

Defendants.

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Plaintiff KRISTINA Y. DAVIS ("Plaintiff") and Defendant THE JACKSON

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LABORATORY ("Defendant"), by and between their respective attorneys of record, hereby

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stipulate as follows:

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1.

On August 3 and 4, 2012, Defendant took the deposition of Plaintiff. During the

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deposition, a dispute occurred between the parties as to a line of questioning involving alcohol

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and Plaintiff was instructed not to answer.

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S HAW V ALENZA LLP
A TTORN E YS A T L A W
S A N F RA N C I S C O

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STIPULATION AND ORDER TO PERMIT
LIMITED DISCOVERY BEYOND DISCOVERY
DEADLINE

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2.

On August 7, 2012, Defendant’s attorney Amy K. Lee, Esq. sent Plaintiff’s

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attorney Leo F. Donahue, Esq. meet and confer correspondence regarding the alcohol-related line

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of questioning.

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3.

On August 14, 2012, Mr. Donahue wrote a response to Ms. Lee’s meet and confer

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correspondence. On that same date, Mr. Donahue and Ms. Lee met and conferred over the

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telephone. During the meet and confer telephone conversation, the parties agreed that they will

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engage in and conclude good faith settlement discussions by August 24, 2012 and will stay the

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issue as to alcohol-related questioning at Plaintiff’s deposition until then.

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4.

The discovery cut-off in this case is September 21, 2012.

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5.

The parties agree that discovery motions and Plaintiff’s deposition related to any

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alcohol-related line of questioning will not be subject to the September 21, 2012 discovery cut-

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off. As to the alcohol-related issue only, the discovery deadline will remain open until the court

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rules on whether the alcohol-related questions are permitted at Plaintiff’s deposition, and

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Plaintiff’s deposition has concluded as to that issue only (if the court permits any questioning).

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All other discovery must be completed by the September 21, 2012 discovery cut-off.

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SO STIPULATED:

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Dated: August 16, 2012

SHAW VALENZA LLP

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By: /s/Amy K. Lee ____________
D. Gregory Valenza
Amy K. Lee
Attorneys for Defendant
THE JACKSON LABORATORY

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Dated: August 16, 2012

LEO F. DONAHUE, INC.

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By: /s/Leo F. Donahue
Leo F. Donahue
Kevin W. Harris
Attorneys for Plaintiff
Kelly Keehner

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A TTORN E YS A T L A W
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STIPULATION AND ORDER TO PERMIT
LIMITED DISCOVERY BEYOND DISCOVERY
DEADLINE

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ORDER

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Pursuant to the parties' Stipulation, and GOOD CAUSE APPEARING therefore:

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IT IS HEREBY ORDERED that discovery motions and Plaintiff’s deposition related to

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any alcohol-related line of questioning will not be subject to the September 21, 2012 discovery

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cut-off. As to the alcohol-related issue only, the discovery deadline will remain open until the

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court rules on whether the alcohol-related questions are permitted at Plaintiff’s deposition, and

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Plaintiff’s deposition has concluded as to that issue only (if the court permits any questioning).

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All other discovery must be completed by the September 21, 2012 discovery cut-off.

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IT IS SO ORDERED.

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Dated: August 23, 2012
__________________________________
MORRISON C. ENGLAND, JR
UNITED STATES DISTRICT JUDGE

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DEAC_Signatu re-END:

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STIPULATION AND ORDER TO PERMIT
LIMITED DISCOVERY BEYOND DISCOVERY
DEADLINE