Lota v. Home Depot U.S.A., Inc.
Filing
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STIPULATION and ORDER extending time for submission of briefs re: petition for guardian ad litem re 33 . Plaintiff may file his brief within 5 days of the stipulated protective order being entered. Defendant may file a brief within days after receiving Plaintiff's brief. Signed by Judge Laurel Beeler on 5/25/2012. (lblc2, COURT STAFF) (Filed on 5/25/2012)
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Victor C. Thuesen, Esq., #92467
LAW OFFICES OF VICTOR C. THUESEN
11 Western Avenue
Petaluma, California 94952
Telephone: (707) 763-5030
Fax: (707) 763-1848
vthuesen@sbcglobal.net
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Attorney for Plaintiff MIGUEL LOT A
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Andrew J. Jaramillo, CA Bar No. 198303
andrew. iaramill01ogletreedeakins.com
John G. Lee, CA ar No. 238899
john.lee@ogletreedeakins.com
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone: (415) 442-4810
Fax: (415) 442-4870
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Attorneys for Defendant HOME DEPOT U.S.A., INC.
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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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MIGUEL LOT A,
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Plaintiff,
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vs.
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HOME DEPOT U.S.A., INC., and
DOES 1 through 20,
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Defendants.
C 11-05777 YGR LB
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Case No.:
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STIPULATED REQUEST TO
EXTEND TIME FOR SUBMISSION
OF BRIEFS PURSUANT TO ORDER
RE FURTHER SUBMISSIONS IN
SUPPORT OF PETITION FOR
APPOINTMENT OF GUARDIAN
AD LITEM (ECF 27)
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Plaintiff MIGUEL LOTA and Defendant HOME DEPOT U.S.A., INC., through their
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respective counsel, submit this stipulated joint request to again extend the time for submission
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of briefs and materials in further support of or opposition to the pending Petition For
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Appointment of Guardian Ad Litem in the herein case. Good cause exists for the requested
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extension for the reasons set forth below.
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1.
Plaintiff filed a Petition For Appointment of Guardian Ad Litem on April 15,
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2012. (ECF 19) On April 23, 2012, the court referred the matter to Magistrate Judge Laurel
STIPULA TED REQUEST TO EXTEND TIME FOR SUBMISSION OF BRIEFS AND (PROPOSED) ORDER
CASE NO.: C 11 05777 YGR
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Beeler. (ECF 24) On May 2, 2012, Magistrate Beeler ordered Plaintiff to submit a brief and
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additional declaration(s) setting forth certain additional information by May 18,2012. The
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order also permitted Defendant to respond ifit wished to do so on May 25,2012. (ECF 27)
2.
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On May 17, 2012, Magistrate Beeler extended the dates for submission of
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briefs and additional declaration(s) to May 25, 2012 for Plaintiff and to June 1,2012 for
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Defendant, if it wished to respond. The parties here agree to again extend the dates for the
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reasons set forth herein.
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3.
Plaintiff represents that some or all of the information that Plaintiff intends to
submit is private and confidential and should, in order to protect Plaintiff and his family from
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unnecessary intrusions on their privacy, only be submitted to the court pursuant to the
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provisions of an appropriately worded protective order. Certain of that information resides in
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employment related records which Plaintiff has supplied to Defendant.
4.
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The parties anticipated the need for a protective order and have submitted a
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stipulation for the entry of an agreed protective order to the court. (ECF 29) The parties
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anticipate that the court will issue the protective order but agree that the time for Plaintiffs
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further submissions should be extended for a period of five (5) court days after the issuance of
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either the protective order the parties have submitted or another of the Court's choosing. The
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parties also agree to extend the time for Defendant's responsive submission to a date seven (7)
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court days after the submission of Plaintiffs brief and additional declaration(s).
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IT IS SO STIPULATED.
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Dated: May 23, 2012
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LA W OFFICES OF VICTOR C. THUESEN
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By:
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lsi Victor C. Thuesen
VICTOR C. THUESEN
Attorney for Plaintiff Miguel Lota
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III
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III
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III
STIPULATED REQUEST TO EXTEND TIME FOR SUBMISSION OF BRIEFS AND (PROPOSED) ORDER
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CASE NO.: C 11 05777 YGR
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Dated: May 23,2012
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.e.
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By:
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lsI John G. Lee
Attorneys for Defendant
THE HOME DEPOT U.S.A., INC.
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A TTEST A TION PURSUANT TO GENERAL ORDER 45
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I, Victor e. Thuesen, attest that concurrence in the filing of this document has been
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obtained from counsel to Defendant.
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I declare under penalty of perjury that the foregoing is true and correct. Executed on
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May 23,2012 at Petaluma, California.
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(PROPOSED) ORDER
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The Court adopts the Stipulation of the Parties and hereby extends the time for filing of
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Plaintiffs letter brief and declaration(s) to for a period of five (5) court days after the issuance
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of either the protective order the parties have submitted or another of the Court's choosing. The
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parties also agree to extend the time for Defendant's responsive submission to a date seven (7)
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court days after the submission of Plaintiffs brief and additional declaration(s).
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Dated: May 25, 2012
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LAUREL BEELER
United States Magistrate Judge
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STIPULATED REQUEST TO EXTEND TIME FOR SUBMISSION OF BRIEFS AND (PROPOSED) ORDER
CASE NO.: C 11 05777 YGR
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