Equal Employment Opportunity Commission v. Placer ARC

Filing 37

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 7/21/14: Ms. Kazerounian shall be given additional time through August 15, 2014 to review and identify any changes that may be needed to correct her deposition testimony of June 13, 2014. (Kaminski, H)

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

WILLIAM R. TAMAYO, SBN 084965 (CA)
MARCIA L. MITCHELL, SBN 18122 (WA)
DEBRA A. SMITH, SBN 147863 (CA)
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
San Francisco District Office
450 Golden Gate Ave, 5th Fl. West
San Francisco, CA 94102
Telephone No. [phone]
Fax No. [phone]
[e-mail]
Attorneys for Plaintiff EEOC
ROBERT L. REDIGER, ESQ. (CA Bar No. 109392)
LAURA C. MCHUGH, ESQ. (CA Bar No. 180930)
CANDICE K. REDIGER, ESQ. (CA Bar No. 287146)
REDIGER, McHUGH & OWENSBY, LLP
555 Capitol Mall, Suite 1240
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Attorney for Defendant,
PLACER ARC

14
15

UNITED STATES DISTRICT COURT

16

EASTERN DISTRICT OF CALIFORNIA

17
18

Case No.: 2:13-cv-0577-KJM-EFB

U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,

19
Plaintiff,

20
21
22
23
24

JOINT STIPULATION TO EXTEND
TIME PURSUANT TO FED. R. CIV. P.
30(e) TO REVIEW DEPOSITION
TRANSCRIPT and [Proposed] ORDER
PURSUANT TO EASTERN DISTRICT
LOCAL RULE 144

vs.
PLACER ARC d/b/a PLACER ADVOCACY
RESOURCES & CHOICES,

The Honorable Kimberly J. Mueller

Defendant.

25

Magistrate Judge Edmund F. Brennan

26
27
28
JOINT STIPULATION TO EXTEND TIME

1

Case No. 2:13-cv-00577-KJM-EFB

1
2

Whereas the continuation of Charging Party Homeyra Kazerounian’s deposition took place
on June 13, 2014;

3

Whereas Plaintiff EEOC received a copy of Ms. Kazerounian’s deposition transcript on June

4

24, 2014 and Ms. Kazerounian has thirty days from this date to review her deposition transcript

5

pursuant to Federal Rule of Civil Procedure 30(e);

6
7

Whereas Plaintiff’s counsel, Debra A. Smith, was on family medical leave in Florida from
June 14 through June 28, 2014;

8
9

Whereas Plaintiff EEOC inadvertently failed to provide a copy of Ms. Kazerounian’s
transcript to her during Ms. Smith’s absence;

10
11

Whereas Ms. Smith was unaware that a copy of Ms. Kazerounian’s transcript had not been
mailed to Ms. Kazerounian while Ms. Smith was on leave;

12

Whereas Ms. Smith first learned that Ms. Kazerounian did not receive a copy of her

13

transcript until July 10, 2014 when she was anticipating receiving any corrections Ms. Kazerounian

14

may have made;

15
16

Whereas Ms. Smith is scheduled to take another two week medical leave of absence
beginning July 14 through July 28, 2014;

17
18

Whereas it would be extremely difficult for Ms. Kazerounian to review her 285 page
deposition transcript in English within the next few days before Ms. Smith goes on leave; and

19

Whereas Plaintiff EEOC and Defendant Placer ARC d/b/a Placer Advocacy, Resources and

20

Choices (Placer ARC) both agree that an extension of the Fed. R. Fed. P. 30(e) thirty day deadline

21

though August 15, 2014, approximately three additional weeks, would allow Ms. Kazerounian

22

sufficient time to review her deposition and Ms. Smith sufficient time to review any changes Ms.

23

Kazerounian may make without imposing any undue burden on any of the parties, it is therefore:

24

STIPULATED by and between the undersigned counsel that, pursuant to Rule 30(e) of the

25

Federal Rules of Civil Procedure and Local Rule 144(a) of the Eastern District of California, Ms.

26

///

27

///

28

///

JOINT STIPULATION TO EXTEND TIME

2

Case No. 2:13-cv-00577-KJM-EFB

1

Kazerounian be given additional time through August 15, 2014 to review and identify any changes

2

that may be needed to correct her deposition testimony of June 13, 2014.

3
4
5
6
7
8

EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

REDIGER, McHUGH & OWENSBY, LLP

/s/ Debra A. Smith_________________
DEBRA A. SMITH
Attorney for Plaintiff EEOC

/s/ Robert L. Rediger__________________
ROBERT L. REDIGER
Attorney for Defendant Placer ARC

DATED: July 11, 2014.

DATED: July 11, 2014.

9
IT IS SO ORDERED.
10
11

DATED: July 21, 2014.

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
JOINT STIPULATION TO EXTEND TIME

3

Case No. 2:13-cv-00577-KJM-EFB