Gaytan v. Solis

Filing 82

STIPULATION AND ORDER re 81 Proposed Order filed by Richard Gaytan, Hilda Solis. Signed by Judge ARMSTRONG on 10/18/11. (lrc, COURT STAFF) (Filed on 10/20/2011)

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MELINDA HAAG (SBN 132612)
United States Attorney
JOANN M. SWANSON (SBN 88143)
Chief, Civil Division
MICHAEL T. PYLE (SBN 172954)
Assistant United States Attorney

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150 Almaden Blvd., Suite 900
San Jose, California 95113
Telephone: [phone]
FAX: [phone]
[e-mail]

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Attorneys for Defendant Hilda Solis, Secretary of Labor
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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RICHARD GAYTAN,
Plaintiff,

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v.

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HILDA SOLIS, Secretary of Labor,
Defendant.

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No. C 07-6367 SBA

STIPULATION AND ORDER TO SET
DATE FOR MR. GAYTAN’S
DEPOSITION AND TO CONTINUE
FACT DISCOVERY AND EXPERT
DISCLOSURES DEADLINE

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IT IS HEREBY STIPULATED by and between the undersigned, subject to the approval
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of the Court, that (1) Mr. Gaytan will be deposed on November 3, 2011 and (2) the deadline for
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completing fact discovery and and expert disclosures is extended from December 23, 2011 to
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January 31, 2012.
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This stipulation was agreed to at the request of counsel for Defendant. Mr. Gaytan had
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been scheduled to be deposed on July 14, 2011, but the deposition was rescheduled at Mr.
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Gaytan’s request. Mr. Gaytan’s deposition has been repeatedly been set and then rescheduled at
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Mr. Gaytan’s request due to personal issues Mr. Gaytan has faced. Mr. Gaytan is available for
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deposition on November 3, 2011. Defendant has been wanting to take Mr. Gaytan’s deposition
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C 07-6367 SBA
STIPULATION AND [PROPOSED] ORDER CONTINUING DISCOVERY/DISCLOSURE DATE

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earlier than that because Defendant will need to conduct some additional discovery after Mr.

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Gaytan’s deposition, the precise nature of which discovery will be dependent upon the content of

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Mr. Gaytan’s testimony. Defendant is willing to proceed with Mr. Gaytan’s deposition on

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November 3, 2011, the date preferable to him, if the fact discovery deadline and expert

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disclosure deadline can be moved to January 31, 2012. The parties do not believe that any other

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dates set by the Court would need to be continued because of this stipulation.

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DATED: October 14, 2011

By:

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___/s/ Richard Gaytan____________
RICHARD GAYTAN
Plaintiff

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MELINDA HAAG
United States Attorney

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DATED: October 14, 2011

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By:

___/s/ Michael T. Pyle____________
MICHAEL T. PYLE
Assistant United States Attorney
Attorneys for Defendant

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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Plaintiff Mr. Gaytan is to be deposed commencing at 11:00 a.m. on November 3, 2011 at

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Defendant counsel’s office. The fact discovery and expert discosure deadline is continued from

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December 23, 2011 to January 31, 2012. All other dates previously set by the Court remain in

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place.

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DATED:10/18/11

_________________________________
HON. SANDRA BROWN ARMSTRONG
United States District Chief Judge

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C 07-6367 SBA
STIPULATION AND [PROPOSED] ORDER CONTINUING DISCOVERY/DISCLOSURE DATE

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UNITED STATES DISTRICT COURT
FOR THE
NORTHERN DISTRICT OF CALIFORNIA

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GAYTAN et al,
Case Number: CV07-06367 SBA

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Plaintiff,

CERTIFICATE OF SERVICE

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v.
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SOLIS et al,
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Defendant.
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/

I, the undersigned, hereby certify that I am an employee in the Office of the Clerk, U.S. District
Court, Northern District of California.
That on October 20, 2011, I SERVED a true and correct copy(ies) of the attached, by placing
said copy(ies) in a postage paid envelope addressed to the person(s) hereinafter listed, by
depositing said envelope in the U.S. Mail, or by placing said copy(ies) into an inter-office
delivery receptacle located in the Clerk's office.

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Richard Gaytan
433 Red Lion Way
Newman, CA 95360
Dated: October 20, 2011
Richard W. Wieking, Clerk
By: LISA R CLARK, Deputy Clerk

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C 07-6367 SBA
STIPULATION AND [PROPOSED] ORDER CONTINUING DISCOVERY/DISCLOSURE DATE

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