Filed: Feb. 07, 2013
Latest Update: Feb. 07, 2013
Summary: STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE SET FOR FEBRUARY 28, 2013 AND ADR DEADLINES EDWARD M. CHEN, District Judge. Defendant Leon Panetta, Secretary of Defense ("Secretary") and Plaintiffs Mary Jennings Hegar, Jennifer Hunt, Alexandra Zoe Bedell, Colleen Farrell, and Service Women's Action Network (collectively, "the parties"), by and through their respective counsel, hereby stipulate as follows: 1. On November 27, 2012, Plaintiffs filed their Complain
Summary: STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE SET FOR FEBRUARY 28, 2013 AND ADR DEADLINES EDWARD M. CHEN, District Judge. Defendant Leon Panetta, Secretary of Defense ("Secretary") and Plaintiffs Mary Jennings Hegar, Jennifer Hunt, Alexandra Zoe Bedell, Colleen Farrell, and Service Women's Action Network (collectively, "the parties"), by and through their respective counsel, hereby stipulate as follows: 1. On November 27, 2012, Plaintiffs filed their Complaint..
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE SET FOR FEBRUARY 28, 2013 AND ADR DEADLINES
EDWARD M. CHEN, District Judge.
Defendant Leon Panetta, Secretary of Defense ("Secretary") and Plaintiffs Mary Jennings Hegar, Jennifer Hunt, Alexandra Zoe Bedell, Colleen Farrell, and Service Women's Action Network (collectively, "the parties"), by and through their respective counsel, hereby stipulate as follows:
1. On November 27, 2012, Plaintiffs filed their Complaint for Declaratory and Injunctive Relief challenging as unconstitutional the 1994 direct ground combat definition and assignment rule, and the Court issued the Order Setting Initial Case Management Conference and ADR Deadlines establishing the following scheduling dates:
2/7/2013 Last day to: meet and confer re: initial disclosures, early settlement, ADR process selection, and discovery plan; file ADR Certification signed by Parties and Counsel; file either Stipulation to ADR Process or Notice of Need for ADR Phone Conference
2/21/2013 Last day to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report, and file Case Management Statement per the Court's Standing Order re Contents of Joint Case Management Statement
2/28/2013 Initial Case Management Conference
3. On January 24, 2013, the Secretary rescinded the 1994 direct ground combat definition and assignment rule and directed the Military Services to submit plans to him by May 15, 2013, for implementation of this policy change;
4. In light of the above, on January 29, 2013, the parties filed a stipulation with the Court agreeing to meet and confer within three weeks of the deadline for submitting the implementation plans and to allow the Secretary thirty (30) days after that meet and confer to respond to the Complaint;
5. The parties now request that the Court continue the scheduling dates established by the November 27, 2012 Order so that they will occur after the parties meet and confer following the May 15, 2013 deadline for the Military Services' submission of their implementation plans. Specifically, the parties request that: the February 7, 2013 deadline for them to meet and confer and to file ADR-related materials be continued to June 15, 2013; that the Initial Case Management Conference be continued from February 28, 2013 to July 18, 2013, which is seventeen days after the Secretary's response to the Complaint is due; and that the deadline for the parties' Rule 26(f) Report, initial disclosures or statement of objection in Rule 26(f) Report, and Case Management Statement be continued to July 11, 2013.
ACCORDINGLY, the parties respectfully request that the Court revise the initial case management conference and ADR deadlines set forth in the November 27, 2012 Order as follows:
6/15/2013 Last day to: meet and confer re: initial disclosures, early settlement, ADR process selection, and discovery plan; file ADR Certification signed by Parties and Counsel; file either Stipulation to ADR Process or Notice of Need for ADR Phone Conference
7/11/2013 Last day to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report, and file Case Management Statement per the Court's Standing Order re Contents of Joint Case Management Statement
7/18/2013 Initial Case Management Conference
IT IS SO STIPULATED.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
The initial case management conference and ADR deadlines are revised as follows:
6/15/2013 Last day to: meet and confer re: initial disclosures, early settlement, ADR process selection, and discovery plan; file ADR Certification signed by Parties and Counsel; file either Stipulation to ADR Process or Notice of Need for ADR Phone Conference
7/11/2013 Last day to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report, and file Case Management Statement per the Court's Standing Order re Contents of Joint Case Management Statement
7/18/2013 Initial Case Management Conference
