Davies v. DelaVega et.al.

Filing 71

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 3/27/2017 and agreed between the parties. Plaintiff shall have until 4/15/2017 and Dr. Crosson shall have until 4/15/2017 to serve their responses to the first set of written discovery requests. Discover will close on 5/14/2017. All motions to compel must be filed by that date.(Yin, K)

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XAVIER BECERRA, State Bar No. 118517
Attorney General of California
JON S. ALLIN, State Bar No. 155069
Supervising Deputy Attorney General
MAUREEN C. ONYEAGBAKO, State Bar No. 238419
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendant Crosson

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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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AVON DAVIES,

2:14-CV-2831 CKD (P)

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Plaintiff, STIPULATION TO EXTEND TIME TO
SERVE DISCOVERY RESPONSES;
ORDER

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v.
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M. DE LA VEGA, et al.,

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Judge:
Hon. Carolyn K. Delaney
Trial Date:
N/A
Defendants. Action Filed: December 4, 2014

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1.

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Plaintiff Avon Davies and Defendant Dr. Crosson stipulate to extend the time for

responding to the first set of written discovery requests by twenty-one days.
2.

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On February 3, 2017, Dr. Crosson served his first set of Interrogatories and

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Requests for Production of Documents on Plaintiff. Plaintiff’s deadline for serving responses by

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mail is March 23, 2017. (See Discovery and Scheduling Order 4:21-22, ECF No. 61, Dec. 29,

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2016.)

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3.

On February 5, 2017, Plaintiff served his first set of Interrogatories, Requests for

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Production of Documents, and Requests for Admissions on Dr. Crosson. Dr. Crosson’s deadline

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for serving responses by mail is March 25, 2017. (See id.)

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1
Stip. to Extend Time to Serve Disc. Resps.; [Proposed] Order (2:14-CV-2831 CKD (PC))

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4.

After each party served their written discovery requests but before the responses

were due, Dr. Crosson changed counsel.
5.

Dr. Crosson’s new counsel has worked diligently to get up to speed on the case but

needs additional time to investigate and complete Dr. Crosson’s discovery responses.
6.

On March 20, 2017, Plaintiff and Dr. Crosson’s new attorney conferred and agreed

to a twenty-one-day extension of time to respond to the aforementioned discovery requests. This
extension gives Plaintiff until April 13, 2017 and Dr. Crosson until April 15, 2017, to respond to
the first set of written discovery requests.
7.

In order to accommodate the additional time for serving discovery responses,

Plaintiff does not object to Dr. Crosson’s anticipated motion to modify the Discovery and
Scheduling Order to extend the deadlines for completing discovery, including motions to compel,
and for filing pre-trial motions by forty-seven days.
SO STIPULATED.

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Dated: March ___, 2017

Respectfully submitted,

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___________________________________
AVON DAVIES (CDCR NO. J-42775)
Plaintiff Pro Se

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Dated: March ___, 2017

Respectfully submitted,

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XAVIER BECERRA
Attorney General of California
JON S. ALLIN
Supervising Deputy Attorney General

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___________________________________
MAUREEN C. ONYEAGBAKO
Deputy Attorney General
Attorneys for Defendant Crosson

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SA2017303566
32809104.doc

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Stip. to Extend Time to Serve Disc. Resps.; [Proposed] Order (2:14-CV-2831 CKD (PC))

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ORDER
In accordance with the parties’ foregoing stipulation, and good cause appearing, the time
for each party to respond to the first set of written discovery requests shall be extended by twentyone days. Plaintiff shall have until April 13, 2017 and Dr. Crosson shall have until April 15,
2017, to serve their responses to the first set of written discovery requests. Discovery will close
on May 14, 2017. All motions to compel must be filed by that date.

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IT IS SO ORDERED.
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Dated: March 27, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stip. to Extend Time to Serve Disc. Resps.; [Proposed] Order (2:14-CV-2831 CKD (PC))