Universal Protection Service, LP v. Ave Seltsam

Filing 37

ORDER by Judge Haywood S. Gilliam, Jr. Granting 34 Stipulation. *This order terminates docket no. 17 as moot.*(ndr, COURT STAFF) (Filed on 9/19/2022)

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1 2 3 4 5 6 7 8 9 10 11 JEREMY T. NAFTEL (SBN 185215) jnaftel@martensonlaw.com LAUREN B. KALFSBEEK (SBN 322153) lkalfsbeek@martensonlaw.com ALEX A. SMITH (SBN 317224) alexsmith@martensonlaw.com MARTENSON, HASBROUCK & SIMON LLP 455 Capitol Mall, Suite 400 Sacramento, California 95814 Telephone: (916) 970-1434 Facsimile: (404) 909-8120 Attorneys For Plaintiff UNIVERSAL PROTECTION SERVICE, LP D/B/A ALLIED UNIVERSAL SECURITY SERVICES 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 OAKLAND DIVISION 15 16 17 18 19 UNIVERSAL PROTECTION SERVICE, LP d/b/a ALLIED UNIVERSAL SECURITY SERVICES, Plaintiff, 20 21 22 23 24 CASE NO.: 4:22-cv-04927-HSG STIPULATED ORDER GRANTING PLAINTIFF’S MOTION FOR EXPEDITED DISCOVERY v. AVE SELTSAM, Defendant. 25 26 27 28 STIPULATED ORDER GRANTING PLAINTIFF’S MOTION FOR EXPEDITED DISCOVERY 1 2 3 4 5 6 Before this Court is the Plaintiff’s Motion for Expedited Discovery (the “Motion”), seeking expedited discovery. Upon the stipulation and agreement of Plaintiff and Defendant Ave Seltsam (“Defendant”) (collectively, the “Parties”), the Court hereby grants Plaintiff’s Motion. Accordingly, IT IS HEREBY ORDERED: 1. 7 of Ave Seltsam (“Seltsam”) within fourteen (14) days of the Court’s 8 order regarding expedited discovery and, if necessary, prior to 9 Defendant Seltsam’s appearance date. 10 2. 11 prior to the initiation of any other depositions in this matter. 13 3. 14 Plaintiff shall be entitled to issue a subpoena duces tecum and ad testificandum to Defendant’s current employer, GardaWorld. 15 4. 16 Defendant Seltsam shall be permitted to take a deposition of a corporate representative of Plaintiff. 17 5. 18 The Parties may serve no more than ten (10) requests for production of documents and five (5) interrogatories on each other. Defendant 19 must serve any objections to Plaintiff’s First Requests for Production 20 of Documents and First Set of Written Interrogatories to Defendant 21 (“Plaintiff’s Written Discovery”) upon counsel for Plaintiff by 22 Monday, September 19, 2022. Responses to Plaintiff’s Written 23 Discovery must be served upon counsel for Plaintiff by Wednesday, 24 September 21, 2022. Any objections and/or responses to any other 25 discovery requests shall be due no later than seven (7) calendar days 26 28 Plaintiff shall be entitled to take and complete the depositions of Defendant Seltsam and the corporate representative of GardaWorld 12 27 Plaintiff shall be entitled to notice, schedule, and take the deposition after service of such discovery requests. /// 2 STIPULATED ORDER GRANTING PLAINTIFF’S MOTION FOR EXPEDITED DISCOVERY 1 2 3 4 5 6 7 8 9 10 6. The Parties may serve written discovery, deposition notices, and any other discovery material by hand delivery, regular mail, expedited mail, facsimile, or electronic mail, and the party serving such material shall be deemed to have effectuated service in accordance with the Federal Rules of Civil Procedures on the day of its receipt of the material so long as the material is received no later than 5:00 pm pacific time. SIGNED this 19th day of September, 2022. 11 12 13 14 _________________________________________ Hon. Haywood S. Gilliam, Jr. United States District Court for the Northern District of California 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATED ORDER GRANTING PLAINTIFF’S MOTION FOR EXPEDITED DISCOVERY

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