Bhatnagar v. United States of America
Filing
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ORDER GRANTING 73 STIPULATION EXTENDING DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES. Discovery due by 6/24/2016Dispositive Motions due by 7/22/2016Dispositive Motion Hearing set for 9/1/2016 Signed by Judge Maria-Elena James on 1/20/2016. (cdnS, COURT STAFF) (Filed on 1/20/2016)
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Stephanie P. Skaff (SBN 183119)
sskaff@fbm.com
Alex Reese (SBN 280530)
areese@fbm.com
Julia F. Kropp (SBN 298363)
jkropp@fbm.com
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FARELLA BRAUN + MARTEL LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
Telephone: (415) 954-4400
Facsimile: (415) 954-4480
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Attorneys for Plaintiff
Sanjay Bhatnagar
Brian J. Stretch (SBN 163973)
Acting United States Attorney
Alex G. Tse (SBN 152348)
Chief, Civil Division
Robin M. Wall (SBN 235690)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-7071
Fax: (415) 436-6748
Robin.Wall@usdoj.gov
Attorneys for Defendant United States
of America
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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Sanjay Bhatnagar,
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Case No. 14-cv-00327-MEJ
Plaintiff,
vs.
STIPULATION AND (PROPOSED) ORDER
EXTENDING DISCOVERY AND DISPOSITIVE
MOTIONS DEADLINES
The United States of America,
Defendant.
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Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
(415) 954-4400
Stipulation re Discovery and Dispos. Motion
Deadlines / Case No. 14-cv-00327-MEJ
31195\5242168.1
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Whereas, on December 15, 2015, after consulting with counsel for both parties,
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Magistrate Judge Beeler continued the date for the settlement conference in this action to April
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26, 2016 (Dkt. 70);
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Whereas, the new settlement conference date falls just before the deadline for disclosure
of expert witnesses, currently set for April 29, 2016 (Dkt. 65);
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Whereas, in compliance with Judge Beeler’s order, counsel for the parties have met and
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conferred regarding a plan for discovery to occur before the settlement conference, as described
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in the declaration of Alex Reese filed with this stipulation in compliance with Civil L.R. 6-2;
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Whereas, the parties have agreed that extending certain discovery and dispositive motion
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deadlines would better facilitate discovery and allow for meaningful settlement discussion at the
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April 26 conference;
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Whereas, extending the discovery and dispositive motion deadlines would not impact the
December 12, 2016 trial date or any pretrial deadlines in this case;
Therefore, the parties hereby stipulate and agree that the following deadlines are extended
as follows:
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Disclosure of Expert Witnesses: Extended from April 29, 2016 to May 27, 2016;
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•
Disclosure of Rebuttal Expert Witnesses: Extended from May 9, 2016 to June 10,
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2016;
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•
Close of Discovery: Extended from May 24, 2016 to June 24, 2016;
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•
Deadline to File Dispositive Motions: Extended from June 23, 2016 to July 22,
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2016;
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Hearing on Dispositive Motions: Extended from July 28, 2016 at 10:00 a.m. to
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September 1, 2016 at 10:00 a.m. (or any other date that is convenient for the
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Court);
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•
All other dates remain unchanged.
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Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
(415) 954-4400
Stipulation re Discovery and Dispos. Motion
Deadlines / Case No. 14-cv-00327-MEJ
-1-
31195\5242168.1
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January 20, 2016
FARELLA BRAUN + MARTEL LLP
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By: /s/ Alex Reese
Alex Reese
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Attorneys for Plaintiff Sanjay Bhatnagar
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January 20, 2016
BRIAN J. STRETCH
Acting United States Attorney
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By: /s/ Robin M. Wall
Robin M. Wall
Assistant United States Attorney
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Attorneys for Defendant United States of
America
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FILER’S ATTESTATION
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In compliance with Civil L.R. Rule 5-1, I hereby attest that all parties have concurred in
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the filing of this Stipulation and (Proposed) Order Extending Discovery and Dispositive Motion
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Deadlines.
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January 20, 2016
/s/ Alex Reese
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Alex Reese
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(PROPOSED) ORDER
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In accordance with a stipulation between the parties, IT IS ORDERED that the deadlines
for discovery and dispositive motions are hereby extended as follows:
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Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
(415) 954-4400
Stipulation re Discovery and Dispos. Motion
Deadlines / Case No. 14-cv-00327-MEJ
-2-
31195\5242168.1
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Disclosure of Expert Witnesses: Extended from April 29, 2016 to May 27, 2016;
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Disclosure of Rebuttal Expert Witnesses: Extended from May 9, 2016 to June 10,
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2016;
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•
Close of Discovery: Extended from May 24, 2016 to June 24, 2016;
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•
Deadline to File Dispositive Motions: Extended from June 23, 2016 to July 22,
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2016;
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Hearing on Dispositive Motions: Extended from July 28, 2016 at 10:00 a.m. to
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September 1, 2016 at 10:00 a.m. (or any other date that is convenient for the
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Court);
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•
All other dates remain unchanged.
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January 20
Date: _____________, 2015
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Honorable Maria-Elena James
United States Magistrate Judge
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Farella Braun + Martel LLP
235 Montgomery Street, 17th Floor
San Francisco, CA 94104
(415) 954-4400
Stipulation re Discovery and Dispos. Motion
Deadlines / Case No. 14-cv-00327-MEJ
-3-
31195\5242168.1
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