Opinion
Case No. CV 11-04391 EJD (HRL)
03-14-2013
BOBBY SANDERS, Plaintiff, v. RAYMOND LAHOOD, SECRETARY, UNITED STATES DEPARTMENT OF TRANSPORTATION, Defendant.
MELINDA HAAG (CSBN 132612) United States Attorney ALEX TSE (CSBN 152348) Chief, Civil Division CLAIRE T. CORMIER (CSBN 154364) Assistant United States Attorney Attorneys for Defendant Raymond LaHood, Secretary, United States Department of Transportation Christopher D. Vaughn Attorney for Plaintiff
MELINDA HAAG (CSBN 132612)
United States Attorney
ALEX TSE (CSBN 152348)
Chief, Civil Division
CLAIRE T. CORMIER (CSBN 154364)
Assistant United States Attorney
Attorneys for Defendant
Raymond LaHood,
Secretary, United States Department of Transportation
STIPULATION AND [PROPOSED]
ORDER EXTENDING DEADLINE FOR
FACT DISCOVERY MOTIONS
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 meet and confer letter to defendant's counsel relating to some previous discovery responses by defendant. In addition, defendant's counsel pointed out some discovery to plaintiff, responses to which are overdue.
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 STIPULATE AND REQUEST that the deadline for filing motions to compel fact discovery be extended to April 11, 2013.
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.
IT IS SO STIPULATED.
Respectfully submitted,
THE VAUGHN LAW FIRM, LLC
____________________
Christopher D. Vaughn
Attorney for Plaintiff
MELINDA HAAG
United States Attorney
By: ____________________
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.
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Assistant United States Attorney
[PROPOSED] ORDER
IT IS SO ORDERED.
____________________
Edward J. Davila
United States District Judge