Opinion
KEVIN D. REESE, TIMOTHY L. REED, OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C., San Francisco, CA, Attorneys for Defendant THE SHERWIN-WILLIAMS COMPANY.
Lawrance A. Bohm, BOHM LAW GROUP, Sacramento, CA, Erik Roper, THE LAW OFFICE OF ERIK ROPER, Sacramento, CA, Attorneys for Plaintiff NATHAN LENARD.
STIPULATION TO CONTINUE HEARING DATE FOR PLAINTIFF'S MOTIONS TO COMPEL AND DEFENDANT'S MOTION FOR PROTECTIVE ORDER; and [PROPOSED] ORDER
ALLISON CLAIRE, Magistrate Judge.
Plaintiff Nathan Lenard ("Plaintiff") and Defendant The Sherwin-Williams Company ("Defendant") submit the following stipulation to continue the November 4, 2015 date for the hearings on Defendant's Motion for Protective Order Regarding Plaintiff's Request for Production of Documents, Set Nos. 4 and 6 (Dkt. No. 29) and Plaintiff's Motion to Compel Amended Responses to Plaintiff's Requests for Production of Documents, Set Nos. 4 and 6; and Motion to Compel Depositions (Dkt. No. 30) ("collectively, the "Discovery Motions").
Since filing the Discovery Motions, the parties have continued to meet and confer in order to resolve the issues presented therein. To date, numerous issues presented by the Discovery Motions have been resolved by the parties through their meet-and-confer efforts. The parties are optimistic that they may resolve all of the issues presented by the Discovery Motions or, at the very least, significantly narrow those issues prior to presenting them to the Court.
On October 23, 2015, Timothy Reed, counsel for Defendant, contacted Deputy Clerk Valerie Callen to request a continuance of the November 4, 2015 hearing date for the Discovery Motions to November 18, 2015. In a responsive voice message, Ms. Callen informed Mr. Reed that the earliest available hearing date is December 2, 2015. Ms. Callen also stated that the parties may file a stipulation to continue the hearings to December 2, 2015.
Accordingly, because a continuance may result in the conservation of judicial resources and those of the parties, Plaintiff and Defendant jointly and respectfully request that the hearings on the Discovery Motions be continued to December 2, 2015.
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED,
The hearings on Defendant's Motion for Protective Order Regarding Plaintiff's Request for Production of Documents, Set Nos. 4 and 6 (Dkt. No. 29) and Plaintiff's Motion to Compel Amended Responses to Plaintiff's Requests for Production of Documents, Set Nos. 4 and 6; and Motion to Compel Depositions (Dkt. No. 30) is hereby continued to December 2, 2015 at 10:00 a.m.