Werdebaugh-v-Blue Diamond Growers
Filing
146
ORDER granting 145 plaintiff's request to enlarge DDJR page limit. Signed by Magistrate Judge Howard R. Lloyd on 7/31/2014. (hrllc2, COURT STAFF) (Filed on 7/31/2014)
LOVELACE AND ASSOCIATES, P.A.
Post Office Box 6205
12870 US Hwy 98 West, Suite 200
Miramar Beach, Florida 32550
Telephone: (850) 837-6020
Facsimile: (850) 837-4093
Dewitt M. Lovelace
Valerie Lauro Nettles
valerie@lovelacelaw.com
S
UNIT
ED
Dear Judge Lloyd:
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lo
ard R. L
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Judge H
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Chris Werdebaugh v. Blue Diamond Growers
Civil Action No. 5:12-CV-02724
RT
Re:
TED
GRAN
NO
The Honorable Howard R. Lloyd
United States Magistrate Judge
San Jose Courthouse, Courtroom 2-5th Floor
280 South 1st Street
San Jose, California 95113
RT
U
O
July 25, 2014
S DISTRICT
TE
C
TA
R NIA
Licensed in Florida & Mississippi
FO
dml@lovelacelaw.com
N
F
D IS T IC T O
R
C
The parties are in receipt of the Court’s Order Re Discovery Dispute Joint Report No. 2
(Doc. # 144). Pursuant to the Order, counsel for Plaintiff is making efforts to schedule a further
meet and confer session with counsel for Defendant so that meaningful negotiation may take
place regarding the discovery requests at issue in this litigation. However, counsel for Defendant
has informed counsel for Plaintiff that the earliest they can meet and confer is July 28, 2014, and
fact discovery closes in this case on August 1, 2014.
In the event of an unsatisfactory result in the upcoming meet and confer session, Plaintiff
seeks leave of Court to file five (5) additional pages in DDJR # 3 in order to fully address the
specific arguments and assertions of Defendant as to the discovery it is willing to provide and the
discovery which it is not willing to provide. Plaintiff makes this request prior to the meet and
confer session with Defendant because time is of the essence, with expert reports due to be filed
on August 15, 2014.
Thank you for your consideration of this matter.
Respectfully submitted,
Dewitt M. “Sparky” Lovelace
Dewitt M. Lovelace (pro hac vice)
LOVELACE LAW FIRM, P.A.
12870 U.S. Hwy 98 West, Suite 200
Miramar Beach, FL 32550
Telephone: (850) 837-6020
Fax: (850) 837-4093
dml@lovelacelaw.com
cc:
All counsel of record
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