Olsen et al v. United States

Filing 33

ORDER by Judge Susan Illston granting 31 Stipulation to extend deadline for USA to produce Rule 30(b)(6) Designee (tfS, COURT STAFF) (Filed on 10/30/2015)

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BRIAN J. STRETCH (CABN 163973)
United States Attorney
ALEX G. TSE (CABN 152348)
Chief, Civil Division
MARK R. CONRAD (CABN 255667)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant
Clayeo C. Arnold (SBN 65070)
Anthony M. Ontiveros (SBN 152758)
Kiersta D. Perlee (SBN 187675)
CLAYEO C. ARNOLD
A PROFESSIONAL LAW CORPORATION
865 Howe Avenue
Sacramento, CA 95825
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]

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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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SAMARN OLSEN and
NEOLANI OLSEN-RODRIGUEZ,

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Plaintiffs,
v.
UNITED STATES OF AMERICA,
Defendant.

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STIP TO CONT. 30(b)(6) DEADLINE
Case No. C 14-05601 SI

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CASE NO. C 14-05601 SI
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE FOR
DEFENDANT UNITED STATES OF
AMERICA TO PRODUCE A RULE
30(B)(6) DESIGNEE

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WHEREAS, on October 20, 2015, the Court issued an order granting Plaintiffs’ motion to

2 compel Defendant to designate a Rule 30(b)(6) witness (or witnesses) to testify on all topics identified in
3 Plaintiffs’ notices not later than October 29, 2015;
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WHEREAS, six deposition are already scheduled to occur in this matter on October 28 and 29;

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WHEREAS, the person most knowledgeable about several of the topics listed in Plaintiffs’ Rule

6 30(b)(6) notices and whom Defendant anticipates designating as its witness to testify about many if not
7 all of these topics is on annual leave and is out of the country on vacation and will not return to work
8 until the beginning of November 2015;
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WHEREAS, the cut-off deadline for fact discovery in this matter is not until January 29, 2015;
NOW, THEREFORE, the parties hereby stipulate and agree that the deadline for Defendant

11 United States of America to produce a Rule 30(b)(6) designee on the topics set forth in Plaintiffs’
12 notices shall be extended to and include November 30, 2015.
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Respectfully submitted,

15 DATED: October 21, 2015

BRIAN J. STRETCH
Acting United States Attorney

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/s/ Mark R. Conrad
MARK R. CONRAD
Assistant United States Attorney

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STIP TO CONT. 30(b)(6) DEADLINE
Case No. C 14-05601 SI

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1 DATED: October 21, 2015
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CLAYEO C. ARNOLD
A Professional Law Corporation

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/s/ Anthony M. Ontiveros
ANTHONY M. ONTIVEROS
Attorney for Plaintiffs

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7 IT IS SO ORDERED.
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10/29/15
Date: ________________________

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_________________________________________
HON. SUSAN ILLSTON
United States District Court Judge

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STIP TO CONT. 30(b)(6) DEADLINE
Case No. C 14-05601 SI

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