Rodriguez v. State of California et al

Filing 73

ORDER GRANTING ADMINISTRATIVE MOTION FOR ORDER EXTENDING DISCOVERY CUT-OFF. The deadline for completion of fact discovery is continued until April 29, 2011, provided such continuance shall not, by itself, constitute good cause to continue any other deadline or date. Signed by Judge Maxine M. Chesney on April 1, 2011. (mmclc1, COURT STAFF) (Filed on 4/1/2011)

Rodriguez v. State of California et al

Doc. 73

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DAVID B. GOODWIN (No. 104469) [e-mail] MATTHEW J. HAWKINSON (No. 248216) [e-mail] COVINGTON & BURLING LLP One Front Street San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff DONALD R. RODRIGUEZ KAMALA D. HARRIS Attorney General for the State of California TYLER B. PON Supervising Deputy Attorney General TOM BLAKE, Deputy Attorney General (No. 51885) [e-mail] 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants James E. Tilton; Michael C. Genest; John Chiang; Louis Debarraicua, M.D.; Filadelfo Valasquez Oandasan Jr., M.D.; Claude Finn; and Sambrajya Lakshmi Palagummi, M.D. IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION DONALD R. RODRIGUEZ, CIVIL NO: C-08-05390 MMC

Plaintiff, ADMINISTRATIVE MOTION AND STIPULATION FOR ORDER v. EXTENDING DISCOVERY CUT-OFF; [Proposed] ORDER JAMES E. TILTON; MICHAEL C. GENEST; JOHN CHIANG; CLAUDE FINN; LOUIS Date: DEBARRAICUA, M.D.; FILADELFO Time:....9:00 a.m. VALASQUEZ OANDASAN JR., M.D.; Judge: Hon. Maxine M. Chesney SAMBRAJYA LAKSHMI PALAGUMMI, Place: Courtroom 7, 19th Floor M.D.; and DOES 1-100 Defendants Case Filed: Trial Date:
1 Administrative Motion and Stipulation for Order Extending Discovery Cutoff; [Proposed] Order (C-08-05390 MMC)
Dockets.Justia.com

December 1, 2008 October 17, 2011

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IT IS HEREBY STIPULATED by and between the parties to this action, by and through their respective counsel of record, as follows: WHEREAS the deadline for completion of fact discovery is currently set for Wednesday, March 30, 2011. WHEREAS Plaintiff Donald R. Rodriguez has been out of contact and, as a result, Plaintiff's counsel has been unable to comply with certain pending discovery requests, including the deposition of Plaintiff, which had been noticed for March 21, 2011. WHEREAS Plaintiff's counsel has made and is making efforts to reestablish contact with the Plaintiff. WHEREAS both sides believe that good cause exists to extend the discovery cut-off by 30 days to provide Plaintiff's counsel sufficient time to establish contact with the Plaintiff and comply with Plaintiff's discovery obligations. THEREFORE THE PARTIES HEREBY JOINTLY AND RESPECTFULLY HEREBY REQUEST that the Court extend the deadline for completion of fact discovery by 30 days, to April 29, 2011.

2 Administrative Motion and Stipulation for Order Extending Discovery Cutoff; [Proposed] Order (C-08-05390 MMC)

1

Respectfully submitted,
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3 Administrative Motion and Stipulation for Order Extending Discovery Cutoff; [Proposed] Order (C-08-05390 MMC)

COVINGTON & BURLING LLP

By: /s/ Matthew J. Hawkinson
MATTHEW J. HAWKINSON Attorneys for Plaintiff DONALD R. RODRIGUEZ DATED: March 29, 2011 KAMALA D. HARRIS Attorney General for the State of California

By /s/ Tom Blake________
TOM BLAKE Attorneys for Defendants James E. Tilton; Michael C. Genest; John Chiang; Louis Debarraicua, M.D.; Filadelfo Valasquez Oandasan Jr., M.D.; Claude Finn; and Sambrajya Lakshmi Palagummi, M.D.

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SF2009403498

[Proposed] ORDER completion Good cause appearing, it is hereby ordered that the deadline for complete of fact discovery in this matter be continued until April 29, 2011. provided such continuance shall not, by itself, , constitute good cause to continue any other deadline or date. IT IS SO ORDERED. Dated: _______ 2011 April 1, By _________________________ MAXINE M. CHESNEY United States District Judge

4 Administrative Motion and Stipulation for Order Extending Discovery Cutoff; [Proposed] Order (C-08-05390 MMC)