Opinion
2:09-CV-3606-KJM-CKD
09-29-2011
HELEN WHELAN, Plaintiff, v. JOHN E. POTTER, Postmaster General of the United States Postal Service, and DOES 1-20 Inclusive, Defendants.
Sean Gavin Attorney for Plaintiff HELEN WHELAN BENJAMIN B. WAGNER United States Attorney J. EARLENE GORDON Assistant U.S. Attorney
BENJAMIN B. WAGNER
United States Attorney
J. EARLENE GORDON
Assistant U. S. Attorney
Attorneys for Defendant
STIPULATION TO EXTEND TIME TO
DEPOSE PLAINTIFF HELEN WHELAN
Plaintiff, Helen Whelan, and Defendant, John E. Potter, Postmaster General, United States Postal Service, by and through their respective counsel, hereby agree, subject to the Court's approval, to extend the time for Defendant to depose Plaintiff Helen Whelan. By stipulation of the parties' counsel, the deadline for Defendant to depose Plaintiff will now be Friday, November 18, 2011. This extension is necessary to give Plaintiff's newly assigned attorney, Sean Gavin, an opportunity to familiarize himself with the file, and clear a time in his schedule to produce Plaintiff for her deposition. Defendant agrees that this request is reasonable.
This stipulation is made and entered into pursuant to the Federal Rules of Civil Procedure, Rule 29(b). This stipulation will not interfere with the time set for completing any other discovery, for hearing a motion, or for trial.
Nothing in this stipulation is intended to abridge or extend any obligations or responsibilities articulated in Federal Rules of Civil Procedure, Rule 30. No extension of time is sought for any other deadline imposed by the Court's Scheduling Order.
Respectfully submitted,
THE LAW OFFICE OF BOWMAN AND ASSOCIATES A Professional Corporation
Sean Gavin
Attorney for Plaintiff
HELEN WHELAN
BENJAMIN B. WAGNER
United States Attorney
J. EARLENE GORDON
Assistant U.S. Attorney
PURSUANT TO THE PARTIES' STIPULATION, IT IS SO ORDERED.
__________________________
UNITED STATES DISTRICT JUDGE