Jenkins v. Kerry

Filing 39

STIPULATION AND ORDER TO CONTINUE DISCOVERY, DISPOSITIVE MOTION, AND TRIAL DATES. Signed by Chief Magistrate Judge Joseph C. Spero on 12/1/16. (klhS, COURT STAFF) (Filed on 12/1/2016)

1 BRIAN J. STRETCH (CABN 163973)
United States Attorney
2
SARA WINSLOW (DCBN 457643)
3 Chief, Civil Division
4 ROBIN M. WALL (CABN 235690)
Assistant United States Attorney
5
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
6
Telephone: [phone]
Fax: [phone]
7
[e-mail]
8
Attorneys for Federal Defendant
9
UNITED STATES DISTRICT COURT
10
NORTHERN DISTRICT OF CALIFORNIA
11
SAN FRANCISCO DIVISION
12
13
ANGELA JENKINS,
14
Plaintiff,
15
v.
16
17
18

JOHN KERRY, SECRETARY, UNITED
STATES DEPARTMENT OF STATE,
Defendant.

19

)
)
)
)
)
)
)
)
)
)
)
)

Case No. 15-cv-01921 RS (JCS)
STIPULATION AND MOTION TO CONTINUE
DISCOVERY, DISPOSITIVE MOTION, AND
TRIAL DATES; [PROPOSED] ORDER

20
21
22
STIPULATION AND MOTION
23
After meeting on December 1, 2016, as ordered by Magistrate Judge Joseph C. Spero, and with
24
the assistance of Judge Spero, the parties have reached agreement regarding an extension of the
25
discovery deadline to permit a number of depositions as listed below.
26
The parties stipulate and agree to continue the discovery deadline to permit the following
27
depositions:
28
STIP. TO CONTINUE SCHEDULE; [PROPOSED] ORDER
15-CV-01921 RS

1
2

EVENT
Deposition of Angela Jenkins
Deposition of Tiffany Bartish

3
4

Deposition of Amha Gezahegn

5
6
7

Deposition of Brian Ray

Deposition of Elizabeth Norris

8
9

Deposition of Susan Moorse

10
11
12
13

DATE
December 20, 2016
January 6, 2017, or January 9, 2017, the
specific date to be confirmed by December
2, 2016
January 10, 2017 or January 25, 2017, to be
determined based on the witness’s
availability
Date to be determined based on the
witness’s availability, but no later than
February 16, 2016
Date to be determined based on the
witness’s availability, but no later than
February 16, 2016
Date to be determined based on Ms.
Moorse’s medical availability. Defendant’s
counsel will help coordinate the scheduling
and inform plaintiff’s counsel when Ms.
Moorse becomes available. If Ms. Moorse
has not become available by February 2,
2017, plaintiff reserves the right to seek a
continuance of the trial date.

14
15 Dated: December 1, 2016

BRIAN J. STRETCH
United States Attorney

16
/s/ Robin M. Wall
ROBIN M. WALL
Assistant United States Attorney
Attorneys for Defendant

17
18
19
20

LAW OFFICES OF MAUREEN E. MCFADDEN

21

/s/ Maureen E. McFadden
MAUREEN E. MCFADDEN
Attorneys for Plaintiff
ANGELA JENKINS

22
23
24
25
26
27
28
STIP. TO CONTINUE SCHEDULE; [PROPOSED] ORDER
15-CV-01921 RS

1

CERTIFICATION

2

Pursuant to Civil L.R. 5-1(i)(3), the undersigned hereby attests that Maureen E. McFadden has

3 concurred in the filing of this document.
4

Dated: December 1, 2016

5

BRIAN J. STRETCH
United States Attorney
/s/ Robin M. Wall
ROBIN M. WALL
Assistant United States Attorney
Attorneys for Defendant

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIP. TO CONTINUE SCHEDULE; [PROPOSED] ORDER
15-CV-01921 RS

[PROPOSED] ORDER

1

Pursuant to the parties’ stipulation and for good cause shown, discovery shall be continued in

2
3

this case to permit the following depositions on the dates and subject to the conditions set forth

4

below:

Deposition of Amha Gezahegn

9
10
11

Deposition of Brian Ray

Deposition of Elizabeth Norris

12
13

Deposition of Susan Moorse

14
15
16
17

20
12/1/16
Dated: _____________________

NO

21

UNIT
ED

IT IS SO ORDERED.

ISTRIC
ES D
TC
AT
T

RT
U
O

19

S

18

Spero
seph C.
Judge Jo C. SPERO
JOSEPH

R NIA

8

FO

7

DATE
December 20, 2016
January 6, 2017, or January 9, 2017, the
specific date to be confirmed by December
2, 2016
January 10, 2017 or January 25, 2017, to be
determined based on the witness’s
availability
Date to be determined based on the
witness’s availability, but no later than
February 16, 2016
Date to be determined based on the
witness’s availability, but no later than
February 16, 2016
Date to be determined based on Ms.
Moorse’s medical availability. Defendant’s
counsel will help coordinate the scheduling
and inform plaintiff’s counsel when Ms.
Moorse becomes available. If Ms. Moorse
has not become available by February 2,
2017, plaintiff reserves the right to seek a
continuance of the trial date.

RT

HON.
United States Magistrate Judge
E
H

22
23
24
25
26
27
28
STIP. TO CONTINUE SCHEDULE; [PROPOSED] ORDER
15-CV-01921 RS

LI

6

EVENT
Deposition of Angela Jenkins
Deposition of Tiffany Bartish

RN

A

5

F
D IS T IC T O
R

C