Elliott et al v. Amador County Unified School District et al

Filing 21

STIPULATION and ORDER 20 signed by Magistrate Judge Dale A. Drozd on 8/27/12; A stipulation has been sought and obtained by the parties, through their respective counsel, that given the date of the upcoming opposition to the motion to dismiss, Defe ndants agree the Deponent will provide responses to these written deposition questions within 7 days after the questions are served via email, excluding weekends and holidays, up to 30 questions; and the parties stipulate that Defendants will keep form related objections (i.e. vague, ambiguous) to a minimum and that interrogatory definitions of terms should not be required unless the question intends for a very particular meaning of a term.(Matson, R)

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Etan E. Rosen, Esq. (SBN 173728)
[e-mail]
Ralph C. Lee, Esq. (SBN 258608)
[e-mail]
BEYER, PONGRATZ & ROSEN
A Professional Law Corporation
3230 Ramos Circle
Sacramento, CA 95827
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs,
MARIE ELLIOTT, ANDREA KRUSE,
PATRICIA ROOTS, and RANDI WILSON

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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MARIE ELLIOTT, ANDREA KRUSE,
PATRICIA ROOTS, and RANDI
WILSON, individually,
Plaintiffs,

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v.

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AMADOR COUNTY UNIFIED
SCHOOL DISTRICT, AMADOR
COUNTY OFFICE OF EDUCATION,
THERESA HAWK, in her individual and
official capacity, and DOES 1 through 50,
inclusive,
Defendants.

) CASE NO.: 2:12-CV-00117-MCE-DAD
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) STIPULATION AND ORDER
) REGARDING WRITTEN DEPOSITION
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On August 14, 2012, Plaintiffs served deposition notices for oral deposition and for the
production of documents on August 30, 2012 for:

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DEPONENT: Defendant, Amador County Unified School District’s, Person Most

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Knowledgeable about any “communications between Amador County Unified School District and

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the Amador County Board of Supervisors REGARDING any or all of the Plaintiffs including

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MARIE ELLIOTT, ANDREA KRUSE, PATRICIA ROOTS, and RANDI WILSON, from January

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2010 through November 10, 2011”; and
-1Stipulation and Order Re: Discovery

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DEPONENT: Defendant, Amador County Office of Education’s, Person Most

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Knowledgeable about any “communications between Defendant, Amador County Office of

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Education, and the Amador County Board of Supervisors REGARDING any or all of the Plaintiffs

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including MARIE ELLIOTT, ANDREA KRUSE, PATRICIA ROOTS, and RANDI WILSON, from

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January 2010 through November 10, 2011.”

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Counsel for Defendants responded in a letter dated August 21, 2012 raising various
objections to the notices.

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Therefore, a stipulation has been sought and obtained by the parties, through their respective

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undersigned counsel, that given the date of the upcoming opposition to the motion to dismiss,

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Defendants agree the Deponent will provide responses to these written deposition questions within

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seven (7) days after the questions are served via email, excluding weekends and holidays, up to thirty

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(30) questions; and the parties stipulate that Defendants will keep form related objections (i.e. vague,

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ambiguous) to a minimum and that interrogatory definitions of terms should not be required unless

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the question intends for a very particular meaning of a term.

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ATTORNEYS FOR DEFENDANTS/DEPONENTS:
Dated: August 23, 2012

_/s/ JASON M. SHERMAN_(as authorized 8/23/12)_

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ALESA SCHACHTER
JASON M. SHERMAN

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ATTORNEYS FOR PLAINTIFFS:
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Dated: August 23, 2012

__/s/ RALPH C. LEE_______

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ETAN E. ROSEN
RALPH C. LEE

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
DATED: August 27, 2012.

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Ddad1\orders.civil\elliott0117.stip.disc.ord

-2Stipulation and Order Re: Discovery