Robinson v. HD Supply, Inc.

Filing 67

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr. on 7/24/2013 ORDERING 66 Discovery shall remain open until 8/30/2013 for the purpose of completing the deposition of Bruce Gagon. Mr. Gagon's deposition will take place in Washingto n State, within 100 miles of his residence; and plaintiff will not request that Mr. Gagon produce documents at his deposition Discovery shall remain open until 8/30/2013 for the purpose of completing Mr. Jenkins' deposition. Plaintiff does not have the ability to produce Mr. Jenkins for his deposition, and will not by this stipulation be required to produce him. Discovery shall remain open until 8/30/2013 for the purpose of completing the deposition of Defendant's expert witness, Dr. Alan E. Brooker. (Reader, L)

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Robert C. Bowman, Jr. (SBN: 232388)
Sean Gavin (SBN: 251124)
THE LAW OFFICE OF BOWMAN & ASSOCIATES
A Professional Corporation
3841 North Freeway Blvd., Suite 185
Sacramento, CA 95834
T: 916.923.2800
F: 916.923.2828
E: [e-mail]
Attorneys for Plaintiff
KRIS ROBINSON

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Brian S. Inamine (State Bar No. 117893)
[e-mail]
Philip J. Bonoli (State Bar No. 188906)
[e-mail]
LECLAIRRYAN, LLP
725 South Figueroa Street, Suite 350
Los Angeles, CA 90017-5455
Telephone: [phone]
Telefax: [phone]
Attorneys for Defendant
HD SUPPLY, INC.

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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KRIS ROBINSON,
Plaintiff,

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STIPULATED PLAN TO COMPLETE
OUTSTANDING DISCOVERY

v.
HD SUPPLY, INC., a corporation,
and DOES 1 through 50, inclusive.

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Case No.: 2:12-CV-00604-GEB-CKD

Defendants.

Trial: February 25, 2014
Discovery Cutoff: July 23, 2013

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WHEREAS the Court’s Status (Pretrial Scheduling) Order in this matter (Docket #17)
provides that all discovery is to be completed by July 23, 2013; and
WHEREAS on July 1, 2013, Plaintiff served on Defendant a Notice of Taking
Robinson v. HD Supply, Inc.
Stipulated Plan to Complete Outstanding Discovery

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Deposition Notice of Bruce Gagon, an employee of Defendant and a percipient witness in this

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case; and

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WHEREAS although Plaintiff’s Deposition Notice scheduled the deposition for July 18,

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2013 in Sacramento, California, Mr. Gagon currently resides in Washington State and is

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unavailable for deposition until after August 1; and

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WHEREAS Defendant wishes to depose an individual named Manuel “Randy” Jenkins,
who is a former employee of Defendant; and

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WHEREAS the Parties have agreed on a plan to complete all outstanding discovery; and

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WHEREAS the Parties wish to avoid wasteful pretrial activities, such as motions to

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compel discovery, and believe that judicial economy is furthered and the burden on the Parties

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and the Court are lessened by STIPULATING AS FOLLOWS:

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1. Discovery shall remain open until August 30, 2013 for the purpose of completing the
deposition of Bruce Gagon.
a. Mr. Gagon’s deposition will take place in Washington State, within 100
miles of his residence; and
b. Plaintiff will not request that Mr. Gagon produce documents at his deposition
2. Discovery shall remain open until August 30, 2013 for the purpose of completing
Mr. Jenkins’ deposition.
a. Plaintiff does not have the ability to produce Mr. Jenkins for his deposition,
and will not by this stipulation be required to produce him.
3. Discovery shall remain open until August 30, 2013 for the purpose of completing the
deposition of Defendant’s expert witness, Dr. Alan E. Brooker.

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Robinson v. HD Supply, Inc.
Stipulated Plan to Complete Outstanding Discovery

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Respectfully Submitted,

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THE LAW OFFICE OF BOWMAN & ASSOCIATES
A Professional Corporation

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Dated: July 23, 2013

By: __/s/ Sean Gavin______________________________
Sean Gavin (SBN: 251124)
Attorney for Plaintiff, KRIS ROBINSON

DATED: July 23, 2013

LECLAIRRYAN, LLP

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By:

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/s/ Brian Inamine____________________________
Brian S. Inamine
Philip J. Bonoli
Attorneys for Defendant
HD SUPPLY, INC.

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IT IS SO ORDERED
Date: 7/24/2013

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___________________________________
GARLAND E. BURRELL, JR.
Senior United States District Judge

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DEAC_Signature-END:

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Robinson v. HD Supply, Inc.
Stipulated Plan to Complete Outstanding Discovery

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