Nazif v. Computer Sciences Corporation

Filing 51

STIPULATION AND ORDER re 50 STIPULATION WITH PROPOSED ORDER to Conduct Depositions Out of Time filed by Computer Sciences Corporation. Signed by Judge Edward M. Chen on 2/24/15. (bpf, COURT STAFF) (Filed on 2/24/2015)

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Susan Kumagai
Cal. Bar No. 127667
[e-mail]
Rebecca K. Kimura
Cal. Bar No. 220420
[e-mail]
LAFAYETTE & KUMAGAI LLP
100 Spear Street, Suite 600
San Francisco, California 94105
T: 415-357-4600 | F: 415- 357-4605
Stephen L. Scott (pro hac vice)
Ala. Bar No. ASB-7280-O62S
[e-mail]
F. Daniel Wood Jr. (pro hac vice)
Ala. Bar No. ASB-6822-D65F
[e-mail]
THE KULLMAN FIRM
600 University Park Place, Suite 340
Birmingham, Alabama 35209
T: 205-871-5858 | F: 205-871-5874
Attorneys for Defendant, Computer Sciences Corporation

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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FRED NAZIF, an individual,

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Plaintiff,
v.
COMPUTER SCIENCES
CORPORATION, a Nevada Corporation,
and DOES 1-50, inclusive,
Defendants.

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Case No. C13-05498 EMC
STIPULATION AND [PROPOSED]
ORDER TO CONDUCT
DEPOSITIONS OUT OF TIME

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COME NOW the parties in this action, Plaintiff Fred Nazif and Defendant Computer
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STIPULATION AND [PROPOSED] ORDER TO CONDUCT DEPOSITIONS OUT OF TIME
NAZIF V. COMPUTER SCIENCES CORPORATION (N.D. CAL., CASE NUMBER C13-05498 EMC)

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Sciences Corporation, through their respective counsel, and hereby stipulate to taking the

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depositions of former CSC Technical Accountant April Hand and former GSS Controller

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Stephanie Mayes two and four days, respectively, beyond the cut-off for non-expert discovery

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and in support thereof say:

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1.

Whereas, April Hand and Stephanie Mayes are both under subpoena for

depositions within the non-expert discovery period in this action.
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Whereas, however, April Hand resides in Homer, Louisiana, which is currently

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experiencing severe winter weather and expected to experience additional severe winter weather,

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which will interfere with the current deposition setting. (For example, CSC’s counsel’s flight

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has already been canceled by the airline, and the witness reports that the courthouse and other

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businesses are closed due to dangerous travel conditions.)

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3.

Whereas, however, Stephanie Mayes’ sister’s death from cancer is imminent and

the likely service arrangements will conflict with the current deposition setting.
4.

Whereas, Ms. Hand has agreed to be deposed on March 11, 2015, Ms. Mayes has

agreed to be deposed on March 13, 2015, and counsel for both parties also agree to these dates.
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And Whereas, non-expert discovery closes in this matter on March 9, 2015, but

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taking these depositions out of time as described herein is not expected to otherwise disrupt the

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Scheduling Order for this case or its timely prosecution.

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IT IS THEREFORE STIPULATED AND AGREED AS FOLLOWS: the depositions of
April Hand and Stephanie Mayes may be taken out of time, as described herein.

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In accordance with Northern District of California General Order 45, the filer of this

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document hereby attests that concurrence in the filing of this document has been obtained from

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the other signatory hereto.

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IT IS SO STIPULATED:

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DATED February 24, 2015

Le Clerc & Le Clerc LLP

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By: /s/ Christopher R. LeClerc
Christopher R. LeClerc, Esq.
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STIPULATION AND [PROPOSED] ORDER TO CONDUCT DEPOSITIONS OUT OF TIME
NAZIF V. COMPUTER SCIENCES CORPORATION (N.D. CAL., CASE NUMBER C13-05498 EMC)

Attorney for Plaintiff, Fred Nazif

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DATED February 24, 2015

The Kullman Firm

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By: /s/ F. Daniel Wood Jr.
F. Daniel Wood Jr. (pro hac vice)

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Attorneys for Defendant,
Computer Sciences Corporation

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STIPULATION AND [PROPOSED] ORDER TO CONDUCT DEPOSITIONS OUT OF TIME
NAZIF V. COMPUTER SCIENCES CORPORATION (N.D. CAL., CASE NUMBER C13-05498 EMC)

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UNIT
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__________________________________
DERED
SO OR
SDistrict Judge
United States
IT I
Edward M. Chen

2/24/15

DATE:_______________________

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S DISTRICT
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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ORDER

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STIPULATION AND [PROPOSED] ORDER TO CONDUCT DEPOSITIONS OUT OF TIME
NAZIF V. COMPUTER SCIENCES CORPORATION (N.D. CAL., CASE NUMBER C13-05498 EMC)