Sanders v. LaHood

Filing 38

Order Granting 36 Stipulation Extending Deadline for Fact Discovery Motions. Signed by Hon. Edward J. Davila on 3/14/2013.(ecg, COURT STAFF) (Filed on 3/14/2013)

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1 2 3 MELINDA HAAG (CSBN 132612) United States Attorney ALEX TSE (CSBN 152348) Chief, Civil Division CLAIRE T. CORMIER (CSBN 154364) Assistant United States Attorney 4 5 6 150 Almaden Blvd., Suite 900 San Jose, California 95113 Telephone: (408) 535-5082 FAX: (408) 535-5081 7 8 Attorneys for Defendant Raymond LaHood, Secretary, United States Department of Transportation 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN JOSE DIVISION 13 BOBBY SANDERS, 14 Plaintiff, 15 v. 16 17 RAYMOND LAHOOD, SECRETARY, UNITED STATES DEPARTMENT OF TRANSPORTATION, 18 Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No. CV 11-04391 EJD (HRL) STIPULATION AND [PROPOSED] XXXXXXXXX ORDER EXTENDING DEADLINE FOR FACT DISCOVERY MOTIONS 19 20 21 22 23 The fact discovery cutoff for this case is March 14, 2013. Accordingly, pursuant to Civil Local Rule 37-3, the deadline for filing motions to compel fact discovery is March 21, 2013. Plaintiff has recently retained new counsel. On March 11, 2013, plaintiff’s counsel sent a 24 meet and confer letter to defendant’s counsel relating to some previous discovery responses by 25 defendant. In addition, defendant’s counsel pointed out some discovery to plaintiff, responses to 26 which are overdue. 27 28 In order to allow for the parties and counsel sufficient time to properly meet and confer and attempt to resolve these matters without intervention by the Court, the parties HEREBY STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR MOTIONS TO COMPEL Case No. CV11-4391 EJD (HRL) -1- 1 STIPULATE AND REQUEST that the deadline for filing motions to compel fact discovery1 be 2 extended to April 11, 2013. 3 IT IS SO STIPULATED. Respectfully submitted, 4 5 DATED: March 13, 2013 THE VAUGHN LAW FIRM, LLC 6 /s/ Christopher D. Vaughn 7 Christopher D. Vaughn Attorney for Plaintiff 8 9 DATED: March 13, 2013 MELINDA HAAG United States Attorney 10 /s/ Claire T. Cormier 11 By: 12 CLAIRE T. CORMIER2 Assistant United States Attorney 13 14 15 XXXXXXXXX [PROPOSED] ORDER 16 IT IS SO ORDERED. 17 18 19 14 DATED: March ___, 2013 20 _________________________________________ Edward J. Davila United States District Judge 21 22 23 24 25 26 27 1 The parties note that, because this case has been assigned to Magistrate Judge Howard Lloyd for discovery purposes, the actual procedure for Court intervention would be a Discovery Dispute Joint Report to Judge Lloyd, rather than a motion to compel. 2 28 I, Claire T. Cormier, hereby attest that I have been authorized to submit the electronic signatures indicated by a “conformed” signature (/s/) within this e-filed document. STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR MOTIONS TO COMPEL Case No. CV11-4391 EJD (HRL) -2-

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