Sanders v. LaHood

Filing 39

STIPULATION AND ORDER excusing counsel from in-person meet and confer requirement. Signed by Magistrate Judge Howard R. Lloyd on March 15, 2013. (hrllc1, COURT STAFF) (Filed on 3/15/2013)

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*E-FILED: March 15, 2013* 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] ORDER EXCUSING COUNSEL FROM IN-PERSON MEET AND CONFER REQUIREMENT 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 have submitted STIPULATION AND [PROPOSED] ORDER RE IN PERSON MEET AND CONFER REQUIREMENT Case No. CV11-4391 EJD (HRL) -1- 1 to Judge Davila a stipulation and proposed order extending the deadline for motions to compel 2 fact discovery. 3 This case is assigned to Magistrate Judge Howard Lloyd for discovery purposes. 4 Accordingly, Judge Lloyd’s Discovery Dispute Joint Report procedures would apply to this case. 5 Because plaintiff’s attorney’s office is in Decatur, Georgia, the parties HEREBY STIPULATE 6 AND REQUEST that they be excused from the requirement for in-person meet and confer prior 7 to the submission of a Discovery Dispute Joint Report. Instead, the parties propose that they be 8 required to participate in telephone meet and confer prior to the submission of a Discovery 9 Dispute Joint Report. 10 IT IS SO STIPULATED. Respectfully submitted, 11 12 DATED: March 13, 2013 THE VAUGHN LAW FIRM, LLC 13 /s/ Christopher D. Vaughn 14 Christopher D. Vaughn Attorney for Plaintiff 15 16 DATED: March 13, 2013 MELINDA HAAG United States Attorney 17 /s/ Claire T. Cormier 18 By: 19 CLAIRE T. CORMIER1 Assistant United States Attorney 20 21 [PROPOSED] ORDER 22 IT IS SO ORDERED. 23 24 25 15 DATED: March ___, 2013 26 _________________________________________ HOWARD R. LLOYD United States Magistrate Judge 27 1 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 RE IN PERSON MEET AND CONFER REQUIREMENT Case No. CV11-4391 EJD (HRL) -2-

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