Russell et al v. United States of America et al

Filing 34

STIPULATION AND ORDER extending certain fact discovery deadlines. Signed by Judge Thelton E. Henderson on 01/04/10. (rbe, COURT STAFF) (Filed on 1/4/2010)

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JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division MICHAEL T. PYLE (CSBN 172954 ) Assistant United States Attorney U.S. Attorney's Office/Civil Division 450 Golden Gate Avenue, 9th Floor San Francisco, California 94102-3495 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Federal Defendants

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SASKIA RUSSELL ET AL., ) ) ) ) ) ) ) ) ) ) No. 08-5651 TEH STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN FACT DISCOVERY DEADLINES

14 Plaintiffs, 15 v. 16 UNITED STATES OF AMERICA, 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28

IT IS HEREBY STIPULATED by and between the undersigned, subject to the Court's approval, that the deadline for Plaintiff to respond to certain written discovery is continued and that the fact discovery deadline of February 1, 2009 is continued such that Defendant may subpoena records from and take depositions of Plaintiffs' current and former health care providers until March 19, 2009. The reason for this stipulation is that Plaintiff has requested an extension of time to respond to written discovery served by Defendant on November 18, 2009 and Defendant is willing to extend the deadline for responses to that written discovery to January 8, 2009 if Defendant can have sufficient time after receiving the discovery responses to subpoena records from, and take depositions of, Plaintiffs' current and former health care providers. This stipulation will also give the parties time to resolve any disputes that arise with respect to
STIP AND [PROPOSED] ORDER EXTENDING CERTAIN FACT DISCOVERY DEADLINES C 0 8 -5 6 5 1 TEH

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Defendant's request for releases from Plaintiffs regarding their medical records. The additional time in this stipulation is also requested because Plaintiffs' counsel will be unavailable until January 4, 2010 and Defendant's counsel will be unavailable between February 8-20, 2010. Dated: December 24, 2009 Respectfully submitted, JOSEPH P. RUSSONIELLO United States Attorney By: /s/ Michael T. Pyle Assistant U.S. Attorney Attorneys for Federal Defendants

Dated: December 24, 2009 11 12 13 14 By:

BRAYTON PURCELL, LLP /s/ Clayton W. Kent Attorneys for Plaintiffs

PURSUANT TO STIPULATION, IT IS SO ORDERED 15 16 17 18 19 20 21 22 23 24 25 26 27 28 continued such that Defendant may subpoena records from, and take depositions of, Plaintiffs' 2010 current and former health care providers on or before March 19, 2009.
No other deadlines, including the trial date of May 18, 2010, shall be changed as a result of this order.

Plaintiff shall respond to Defendant's outstanding written discovery and produce responsive 2010 documents on or before January 8, 2010. The fact discovery deadline of February 1, 2009 is

DATED: 01/04/10

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_____________S___________________ I_ TR HON. THELTON E. ICT HENDERSON ES D C AT United States District Judge T

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