Valerio v. Compass Bank

Filing 66

STIPULATION and ORDER signed by District Judge John A. Mendez on 12/14/16: Defendant shall complete the deposition of Diana Masten, R.N. by February, 28, 2017. The Parties shall meet and confer in good faith and fully cooperate to complete Diana Masten's deposition in a timely manner. (Kaminski, H)

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GAVRILOV & BROOKS
J. EDWARD BROOKS (SBN 247767)
2315 Capitol Avenue
Sacramento, California 95816
Telephone: [phone]
Facsimile: [phone]
Email: [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)
EVAN D. BEECHER (SBN 280364)
801 K Street, Suite 2300
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
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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JOINT STIPULATION AND ORDER
EXTENDING TIME TO COMPLETE
DEPOSITION OF DIANA MASTEN,
R.N.

Plaintiff,
v.

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

GLORIA VALERIO,

COMPASS BANK; and DOES 1-50,
inclusive,

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Defendants.

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Complaint Filed:
Trial Date:

01/31/14
04/24/17

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE DEPOSITION OF DIANA MASTEN

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GLORIA VALERIO (“Plaintiff”) and COMPASS BANK (“Defendant”) (collectively,

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“the Parties”), by and through their undersigned counsel, hereby stipulate and agree as follows:

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WHEREAS, the Parties are have met and conferred on all remaining depositions,

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including expert depositions, that must be completed prior to trial;

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WHEREAS, the Court previously extended the deadline to complete several depositions,
including the deposition of Diana Masten, R.N., to December 31, 2016 (Doc. 62);

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WHEREAS, Ms. Masten, a third-party witness, has informed Defendant she will not be
available for her deposition until January or February, 2017;

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WHEREAS, the Parties are working together to minimize costs and the disruption to

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non-litigant deponents, particularly by seeking to avoid any motion compelling them to

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depositions;

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WHEREAS, the Parties agree Defendant has been diligent in its efforts to complete

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Ms. Masten’s deposition prior to December 31, 2016, but has been hindered by leaves of absence

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and a vacation by Ms. Masten;

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WHEREAS, the Parties agree that prejudice will occur to the other party should they be
unable to complete their respective depositions; and

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WHEREAS, the Parties wish to complete the foregoing deposition without being in
violation of the Court’s Order Extending Time to Complete Depositions (Doc. 62);

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THEREFORE, THE PARTIES STIPULATE AND AGREE, THROUGH THEIR

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RESPECTIVE COUNSEL, THAT THE DEPOSITION OF DIANA MASTEN, R.N.

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SHALL BE COMPLETED NO LATER THAN FEBRUARY 28, 2017.

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE DEPOSITION OF DIANA MASTEN

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THE PARTIES AGREE TO MEET AND CONFER IN GOOD FAITH AND TO

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FULLY COOPERATE SO DIANA MASTEN’S DEPOSITION WILL BE TIMELY

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COMPLETED.

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Dated: December 14, 2016

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GAVRILOV & BROOKS
By: /s/ J. Edward Brooks (as authorized on 12/13/16)
J. Edward Brooks

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Attorneys for Plaintiff
GLORIA VALERIO

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JACKSON LEWIS P.C.

Dated: December 14, 2016
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By: /s/ Evan D. Beecher
Carolyn G. Burnette
Douglas M. Egbert
Evan D. Beecher
Attorneys for Defendant
COMPASS BANK

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE DEPOSITION OF DIANA MASTEN

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ORDER
Based upon the foregoing stipulation of the Parties, and good cause appearing therefor,
IT IS HEREBY ORDERED AS FOLLOWS:

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1. Defendant shall complete the deposition of Diana Masten, R.N. by February, 28, 2017;

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2. The Parties shall meet and confer in good faith and fully cooperate to complete Diana

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Masten’s deposition in a timely manner.

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Dated: 12/14/16

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/s/ John A. Mendez
HON. JOHN A. MENDEZ
JUDGE OF THE U. S. DISTRICT COURT

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4832-8664-1981, v. 1

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JOINT STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE DEPOSITION OF DIANA MASTEN