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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JEREMY T. NAFTEL (SBN 185215)
[e-mail]
LAUREN B. KALFSBEEK (SBN 322153)
[e-mail]
ALEX A. SMITH (SBN 317224)
[e-mail]
MARTENSON, HASBROUCK & SIMON LLP
455 Capitol Mall, Suite 400
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys For Plaintiff
UNIVERSAL PROTECTION SERVICE, LP D/B/A ALLIED UNIVERSAL
SECURITY SERVICES

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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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UNIVERSAL PROTECTION
SERVICE, LP d/b/a ALLIED
UNIVERSAL SECURITY
SERVICES,
Plaintiff,

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CASE NO.: 4:22-cv-04927-HSG
STIPULATED ORDER GRANTING
PLAINTIFF’S MOTION FOR
EXPEDITED DISCOVERY

v.
AVE SELTSAM,
Defendant.

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STIPULATED ORDER GRANTING PLAINTIFF’S MOTION FOR EXPEDITED DISCOVERY

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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.

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of Ave Seltsam (“Seltsam”) within fourteen (14) days of the Court’s

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order regarding expedited discovery and, if necessary, prior to

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Defendant Seltsam’s appearance date.

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2.

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prior to the initiation of any other depositions in this matter.

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3.

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Plaintiff shall be entitled to issue a subpoena duces tecum and ad
testificandum to Defendant’s current employer, GardaWorld.

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4.

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Defendant Seltsam shall be permitted to take a deposition of a
corporate representative of Plaintiff.

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5.

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The Parties may serve no more than ten (10) requests for production
of documents and five (5) interrogatories on each other. Defendant

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must serve any objections to Plaintiff’s First Requests for Production

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of Documents and First Set of Written Interrogatories to Defendant

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(“Plaintiff’s Written Discovery”) upon counsel for Plaintiff by

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Monday, September 19, 2022. Responses to Plaintiff’s Written

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Discovery must be served upon counsel for Plaintiff by Wednesday,

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September 21, 2022. Any objections and/or responses to any other

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discovery requests shall be due no later than seven (7) calendar days

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Plaintiff shall be entitled to take and complete the depositions of
Defendant Seltsam and the corporate representative of GardaWorld

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Plaintiff shall be entitled to notice, schedule, and take the deposition

after service of such discovery requests.
///

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STIPULATED ORDER GRANTING PLAINTIFF’S MOTION FOR EXPEDITED DISCOVERY

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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.

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_________________________________________
Hon. Haywood S. Gilliam, Jr.
United States District Court for the
Northern District of California

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STIPULATED ORDER GRANTING PLAINTIFF’S MOTION FOR EXPEDITED DISCOVERY