Morgan Hill Concerned Parents Association v. California Department of Education

Filing 66

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 10/15/14 ORDERING that the hearing on Plaintiffs' 64 Motion to Compel Defendant to Produce Further Documents is CONTINUED to 11/19/2014 at 10:00 AM in Courtroom 26 (AC) before Magistrate Judge Allison Claire. (Kastilahn, A)

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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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MORGAN HILL CONCERNED PARENTS CASE NO. 2:11-CV-03471-KJM AC
ASSOCIATION, an unincorporated
association, and CONCERNED PARENTS DISCOVERY MATTER
ASSOCIATION, an unincorporated
association,
PLAINTIFFS’ AND DEFENDANT’S
STIPULATION AND ORDER CONTINUING
Plaintiffs,
THE HEARING DATE ON PLAINTIFFS’
MOTION TO COMPEL
v.
Courtroom:
26
CALIFORNIA DEPARTMENT OF
Judge:
Honorable Allison Claire
EDUCATION, and DOES 1 through 5,
Magistrate Judge
Hearing Date:
October 22, 2014
Defendants.
Hearing Time:
10:00 a.m.
Action Filed:
April 23, 2012

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-1SAGY LAW
ASSOCIATES

PLAINTIFFS’ AND DEFENDANT’S JOINT STATEMENT OF DISCOVERY DISAGREEMENTS
MHCPA & CPA v. CDE CASE#2:11-CV-03471-KJM-AC

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Pursuant to Rule 230(f) of the Local Rules of the District Court for the Eastern District of
California, Plaintiffs Morgan Hill Concerned Parents Association and Concerned Parents
Association and Defendant California Department of Education (CDE) hereby stipulate to, and
seek the Court’s Order granting, a continuance of Plaintiffs’ Motion to Compel Further
Production of Documents in Response to Plaintiffs’ First and Second Set of Requests, from the
presently pending hearing date of October 22, 2014, to November 19, 2014. Plaintiffs believe
that the continuance will further the goals of the efficient production of discovery and could result
in the elimination of any need to petition the Court for resolution of the parties’ outstanding
discovery disputes.

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On October 10, 2014, counsel for the respective parties engaged in a far-ranging
discussion of the issues implicated by Plaintiffs’ Motion to Compel. The parties are continuing to
work toward resolution of the issues raised in the motion and believe most of the issues raised in
the motion can be resolved informally, obviating the need for the Court’s intervention on those
issues.
Based on the foregoing, THE PARTIES STIPULATE AND AGREE that a continuance
of Plaintiffs’ Motion to Compel from October 22, 2014 to November 19, 2014 will advance the
goals of judicial efficiency and the consensual resolution of discovery disputes.
DATED: October 14, 2014

SAGY LAW ASSOCIATES

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By: ___/S/ Rony Sagy ________________

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RONY SAGY
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Attorneys for Plaintiffs MORGAN HILL
CONCERNED PARENTS
ASSOCIATION and CONCERNED
PARENTS ASSOCIATION

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-2SAGY LAW
ASSOCIATES

PLAINTIFFS’ AND DEFENDANT’S JOINT STATEMENT OF DISCOVERY DISAGREEMENTS
MHCPA & CPA v. CDE CASE#2:11-CV-03471-KJM-AC

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Dated:

KAMALA D. HARRIS
Attorney General of California
ISMAEL A. CASTRO
Supervising Deputy Attorney General

October 14, 2014

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/S/ Brenda A. Ray

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BRENDA A. RAY
Deputy Attorney General
Attorneys for Defendant
California Department of Education

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GOOD CAUSE APPEARING THEREFOR, THE COURT HEREBY ORDERS that
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the hearing on Plaintiffs’ Motion to Compel Defendant to Produce Further Documents in
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Response to Plaintiffs’ Requests to produce should be, and hereby is, continued from October 22,
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2014 at 10:00 a.m. before this Court to November 19, 2014 at 10:00 a.m. before this Court.
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IT IS SO ORDERED.
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Date: October 15, 2014
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-3SAGY LAW
ASSOCIATES

PLAINTIFFS’ AND DEFENDANT’S JOINT STATEMENT OF DISCOVERY DISAGREEMENTS
MHCPA & CPA v. CDE CASE#2:11-CV-03471-KJM-AC