Valerio v. Compass Bank

Filing 49

ORDER signed by District Judge John A. Mendez on 3/31/2016 ORDERING Plaintiff Gloria Valerio shall complete her deposition in this matter by 4/22/2016; any violation of the Parties' Stipulation and/or this Order shall subject theoffending party to appropriate sanctions, as determined by the Court. (Reader, L)

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GAVRILOV & BROOKS
J. EDWARD BROOKS (SBN 247767)
CECILIA L. MARTIN (SBN 301027)
2315 Capitol Avenue
Sacramento, California 95816
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff
GLORIA VALERIO

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JACKSON LEWIS P.C.
CAROLYN G. BURNETTE (SBN 191294)
DOUGLAS M. EGBERT (SBN 265062)
801 K Street, Suite 2300
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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Attorneys for Defendant
COMPASS BANK

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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Case 2:14-CV-00741-JAM-KJN

GLORIA VALERIO,
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JOINT STIPULATION AND ORDER
EXTENDING TIME TO
COMPLETE PLAINTIFF’S
DEPOSITION

Plaintiff,
v.
COMPASS BANK; and DOES 1-50,
inclusive,

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Complaint Filed:
Trial Date:

01/31/14
04/24/17

Defendants.

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE PLAINTIFF’S DEPOSITION

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I.

STIPULATION REGARDING PLAINTIFF’S DEPOSITION

GLORIA VALERIO (“Plaintiff”) and COMPASS BANK (“Defendant”) (collectively,
“the Parties”), by and through their undersigned counsel, hereby stipulate and agree as follows:
WHEREAS, the Parties requested by stipulation that the Court Order Plaintiff to complete
her deposition by April 1, 2016 (“Stipulation”).
WHEREAS, this Court signed the Stipulation on February 4, 2016, Ordering that Plaintiff
complete her deposition by April 1, 2016 (“Order”).

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WHEREAS, the Parties made a good faith effort to complete Plaintiff’s deposition by the

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Ordered deadline (including by completing a substantial portion of the deposition testimony), but

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have determined that they cannot do so because of: (1) various scheduling conflicts (including

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with Plaintiff’s school schedule); and (2) the substantial amount of evidentiary materials that need

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to be covered.

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WHEREAS, the Parties wish to avoid a situation where they are not in compliance with
the Order.
THE PARTIES THEREFORE STIPULATE AND AGREE, THROUGH THEIR

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RESPECTIVE COUNSEL, THAT PLAINTIFF SHALL COMPLETE HER DEPOSITION

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IN ITS ENTIRETY BY APRIL 22, 2016. THE PARTIES FURTHER

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AGREE THAT THEY WILL MEET AND CONFER IN GOOD FAITH TO IDENTIFY

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ADDITIONAL TIMES/DATES THAT: (1) ARE ON OR BEFORE APRIL 22, 2016;

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(2) ARE MUTUALLY AGREEABLE; AND (3) TAKE INTO ACCOUNT PLAINTIFF’S

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SCHOOL SCHEDULE.

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Dated: March 30, 2016

GAVRILOV & BROOKS

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By: /s/ Cecilia L. Martin (authorized on 3/30/16)
J. Edward Brooks
Cecilia L. Martin
Attorneys for Plaintiff
GLORIA VALERIO

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE PLAINTIFF’S DEPOSITION

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Dated: March 30, 2016

JACKSON LEWIS P.C.

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By: /s/ Carolyn G. Burnette
Carolyn G. Burnette
Douglas M. Egbert
Attorneys for Defendant
COMPASS BANK

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE PLAINTIFF’S DEPOSITION

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ORDER
Based upon the foregoing stipulation of the Parties, and good cause appearing therefor,
IT IS SO ORDERED:
1. Plaintiff Gloria Valerio shall complete her deposition in this matter by

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April 22, 2016;
2. Any violation of the Parties’ Stipulation and/or this Order shall subject the

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offending party to appropriate sanctions, as determined by the Court.

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Dated: 3/31/2016

/s/ John A. Mendez_____________
HON. JOHN A. MENDEZ
U. S. DISTRICT COURT JUDGE

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4826-7288-7599, v. 1

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE PLAINTIFF’S DEPOSITION