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)

*E-FILED: March 15, 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]
ORDER EXCUSING COUNSEL FROM
IN-PERSON MEET AND CONFER
REQUIREMENT

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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 have submitted
STIPULATION AND [PROPOSED] ORDER RE IN PERSON MEET AND CONFER REQUIREMENT
Case No. CV11-4391 EJD (HRL)

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to Judge Davila a stipulation and proposed order extending the deadline for motions to compel

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fact discovery.

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This case is assigned to Magistrate Judge Howard Lloyd for discovery purposes.

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Accordingly, Judge Lloyd’s Discovery Dispute Joint Report procedures would apply to this case.

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Because plaintiff’s attorney’s office is in Decatur, Georgia, the parties HEREBY STIPULATE

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AND REQUEST that they be excused from the requirement for in-person meet and confer prior

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to the submission of a Discovery Dispute Joint Report. Instead, the parties propose that they be

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required to participate in telephone meet and confer prior to the submission of a Discovery

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Dispute Joint Report.

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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. CORMIER1
Assistant United States Attorney

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[PROPOSED] ORDER
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IT IS SO ORDERED.
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DATED: March ___, 2013

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_________________________________________
HOWARD R. LLOYD
United States Magistrate Judge

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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 RE IN PERSON MEET AND CONFER REQUIREMENT
Case No. CV11-4391 EJD (HRL)

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