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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MELINDA HAAG (CSBN 132612)
United States Attorney
ALEX TSE (CSBN 152348)
Chief, Civil Division
CLAIRE T. CORMIER (CSBN 154364)
Assistant United States Attorney

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150 Almaden Blvd., Suite 900
San Jose, California 95113
Telephone: [phone]
FAX: [phone]
[e-mail]

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Attorneys for Defendant
Raymond LaHood,
Secretary, United States Department of Transportation

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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BOBBY SANDERS,
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Plaintiff,
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v.
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RAYMOND LAHOOD, SECRETARY,
UNITED STATES DEPARTMENT OF
TRANSPORTATION,

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Defendant.

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Case No. CV 11-04391 EJD (HRL)
STIPULATION AND [PROPOSED]
XXXXXXXXX
ORDER EXTENDING DEADLINE FOR
FACT DISCOVERY MOTIONS

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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

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meet and confer letter to defendant’s counsel relating to some previous discovery responses by

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defendant. In addition, defendant’s counsel pointed out some discovery to plaintiff, responses to

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which are overdue.

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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)

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STIPULATE AND REQUEST that the deadline for filing motions to compel fact discovery1 be

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extended to April 11, 2013.

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IT IS SO STIPULATED.
Respectfully submitted,

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DATED: March 13, 2013

THE VAUGHN LAW FIRM, LLC

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/s/ Christopher D. Vaughn
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Christopher D. Vaughn
Attorney for Plaintiff

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DATED: March 13, 2013

MELINDA HAAG
United States Attorney

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/s/ Claire T. Cormier

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By:
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CLAIRE T. CORMIER2
Assistant United States Attorney

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XXXXXXXXX
[PROPOSED] ORDER

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IT IS SO ORDERED.
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DATED: March ___, 2013

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_________________________________________
Edward J. Davila
United States District Judge

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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.
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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)

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