Keehner v. Jackson Laboratory

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 3/12/2012 ORDERING that any records received from the Employment Development Department will not be subject to the 3/29/2012 discovery cut-off. The discovery deadline will remain open until the documents are received by Defendant as to the Employment Development Department records only. All other discovery must be completed by the 3/29/2012 discovery cut-off. (Zignago, K.)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

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]
Kevin W. Harris, Esq.
Law Offices of Kevin W. Harris
[e-mail]
11344 Coloma Road, Suite 160
Gold River, CA 95670
Tele: [phone]
Fax: [phone]
Attorneys for Plaintiff Kelly Keehner

16

UNITED STATES DISTRICT COURT - EASTERN DISTRICT OF CALIFORNIA

17

SACRAMENTO DIVISION

18
19

KELLY KEEHNER,

20
21

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,

Courtroom 24
Judge:
Hon. Edmund F. Brennan
U.S. Magistrate Judge

22
23
24
25
26

Case No. 2:11-cv-01954-WBS-EFB

Defendants.
Plaintiff KELLY KEEHNER ("Plaintiff") and Defendant THE JACKSON

27

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

28

stipulate as follows:

S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

-1-

STIPULATION AND ORDER TO PERMIT
LIMITED DISCOVERY BEYOND DISCOVERY
DEADLINE

1

1.

On February 23, 2012, Defendant filed and served a Notice of Motion and Motion

2

to Compel Answers to Deposition Questions and Production of Documents to obtain Plaintiff's

3

Employment Development Department records. The Motion to Compel hearing is scheduled to

4

take place on March 21, 2012.

5
6
7

2.

On March 3, 2012, Plaintiff agreed to sign the authorization for release of her

Employment Development Department records.
3.

On March 5, 2012, Defendant's attorney, Amy K. Lee, Esq., learned from the

8

Employment Development Department representative that after receipt of Plaintiff's signed

9

authorization it could take the Employment Development Department months to produce the

10

requested records.

11

4.

The discovery cut-off in this case is March 29, 2012.

12

5.

Pursuant to Local Rule 251, on March 6, 2012, Plaintiff's attorney Leo F.

13

Donahue, Esq. and Defendant's attorney Amy K. Lee, Esq. engaged in the required meet and

14

confer conference to resolve the discovery issues set forth in the Motion to Compel. During the

15

meet and confer conference, Plaintiff's attorney Leo F. Donahue reiterated that Plaintiff will sign

16

the Employment Development Department authorization for release of records.

17

6.

The parties agree that any records received from the Employment Development

18

Department will not be subject to the March 29, 2012 discovery cut-off. The discovery deadline

19

will remain open until the documents are received by Defendant as to the Employment

20

Development Department records only. All other discovery must be completed by the March 29,

21

2012 discovery cut-off.

22

SO STIPULATED:

23

Dated: March 8, 2012

SHAW VALENZA LLP

24
25

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

26
27
28
S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

-2-

STIPULATION AND [PROPOSED] ORDER TO
PERMIT LIMITED DISCOVERY BEYOND
DISCOVERY DEADLINE

1

Dated: March 8, 2012

LEO F. DONAHUE, INC.
LAW OFFICES OF KEVIN W. HARRIS

2
3
By: /s/Leo F. Donahue
Leo F. Donahue
Kevin W. Harris
Attorneys for Plaintiff
Kelly Keehner

4
5
6
7

ORDER

8

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

9

IT IS HEREBY ORDERED that any records received from the Employment Development

10

Department will not be subject to the March 29, 2012 discovery cut-off. The discovery deadline

11

will remain open until the documents are received by Defendant as to the Employment

12

Development Department records only. All other discovery must be completed by the March 29,

13

2012 discovery cut-off.

14

DATED: March 12, 2012.

15
16
17
18
19
20
21
22
23
24
25
26
27
28
S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

-3-

STIPULATION AND [PROPOSED] ORDER TO
PERMIT LIMITED DISCOVERY BEYOND
DISCOVERY DEADLINE