Samuels v. Owens-Brockway Glass Container Inc.

Filing 27

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 11/13/14 ORDERING that the deadline to complete the specified depositions is CONTINUED from the current date of 11/14/14 to 1/31/2015. The parties have further agreed to and propose permitting responses to the specified outstanding written discovery requests to be served on or before 11/19/2014.(Mena-Sanchez, L)

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1 SCHIFF HARDIN LLP Stephen M. Hankins (CSB #154886) 2 shankins@schiffhardin.com Sarah D. Youngblood (CSB #244304) 3 syoungblood@schiffhardin.com One Market Plaza, Spear Street Tower 4 Thirty-Second Floor San Francisco, CA 94015 5 Telephone: 415-901-8700 Facsimile: 415-901-8701 6 Attorneys for Defendant 7 OWENS-BROCKWAY GLASS CONTAINER INC. 8 SANDRA J. COHEN, CA SB#. 85045 300 South First Street, Suite 320 9 San Jose CA 95113 408-975-0545 10 e-mail:sjcohen@employmentatty.com 11 Attorney for Plaintiff ELIZABETH SAMUELS 12 UNITED STATES DISTRICT COURT 13 EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION 14 15 ELIZABETH SAMUELS, Plaintiff, 16 vs. 17 OWENS-BROCKWAY GLASS CONTAINER, INC. and DOES I through V, 18 Defendants. 19 20 CASE NO. 2:13-CV-00713-GEB-DAD STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE SPECIFIED DISCOVERY Judge: Honorable Garland E. Burrell The parties, by and through their attorneys of record have met and conferred and agreed to 21 the following stipulation: 22 (1) On August 14, 2014, pursuant to the parties’ stipulation, the Court entered an order 23 extending the discovery cut-off date to November 14, 2014. See Docket No. 23. 24 (2) The parties desire to take the depositions of certain specified individuals prior to 25 proceeding to trial in this case: Howard Siu, M.D., the Panel Qualified Medical Examiner in 26 plaintiff’s underlying workers’ compensation matters; and Linda Young and Audrey Dean 27 Williams, two fact witnesses identified by plaintiff as having information relevant to her claims. 28 (3) Owing to circumstances beyond the parties’ control, the parties will be unable to 2:13-CV-00713-GEG-DAD 1 STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE SPECIFIED DISCOVERY 1 depose these three individuals prior to the November 14, 2014 discovery cut-off. 2 (4) Howard Siu, M.D. is on a sabbatical and will not be available for deposition until 3 January 2015 at the earliest. 4 (5) Defendant has not been able to effect service of deposition subpoenas upon Linda 5 Young and Audrey Dean Williams. 6 (6) The parties also currently have written discovery requests for which responses are 7 mutually outstanding. 8 (7) With the exception of the specified depositions and outstanding written discovery 9 responses, discovery in this case is otherwise complete. 10 (8) Given the current status of discovery in this case, the fact that the final pretrial 11 conference is set for February 23, 2015, and the fact that trial is not until May 19, 2015, the parties 12 have met and conferred and have agreed that a further extension of the discovery cut-off, for the 13 express, limited purposes of (i) taking the depositions of the three above-named individuals and 14 (ii) responding to the currently outstanding written discovery requests would be in the best interest 15 of each party. 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 2:13-CV-00713-GEG-DAD 2 STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE SPECIFIED DISCOVERY 1 Therefore, the parties have agreed to and propose an extension of the deadline to complete 2 the specified depositions from the current date of November 14, 2014 to January 31, 2015. The 3 parties have further agreed to and propose permitting responses to the specified outstanding 4 written discovery requests to be served on or before November 19, 2014. 5 6 IT IS SO STIPULATED. 7 8 Dated: November 11, 2014 SANDRA J. COHEN 9 11 By: /s/ Sandra J. Cohen (approved 11/11/14) Sandra J. Cohen Attorneys for Plaintiff ELIZABETH SAMUELS 12 Dated: November 11, 2014 SCHIFF HARDIN LLP 10 13 By: /s/ Sarah D. Youngblood Sarah D. Youngblood Attorneys for Defendant OWENS-BROCKWAY GLASS CONTAINER INC. 14 15 16 17 18 PURSUANT TO STIPULATION, IT IS SO ORDERED. 19 Dated: November 13, 2014 20 21 22 23 24 25 26 27 28 2:13-CV-00713-GEG-DAD 3 STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE SPECIFIED DISCOVERY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2:13-CV-00713-GEG-DAD 1 PROOF OF SERVICE TO STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE SPECIFIED DISCOVERY

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