Lota v. Home Depot U.S.A., Inc.

Filing 35

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: [phone]

Fax: [phone]

[e-mail]

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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

[e-mail]

OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.

Steuart Tower, Suite 1300

One Market Plaza

San Francisco, CA 94105

Telephone: [phone]

Fax: [phone]

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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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