Filed: Oct. 05, 2015
Latest Update: Oct. 05, 2015
Summary: STIPULATION AND ORDER REGARDING EXTENSION FOR DISCOVERY CUTOFF MICHAEL J. SENG , Magistrate Judge . The parties hereto, Defendants COUNTY OF STANISLAUS and BIRGIT FLADAGER ("Defendants") and Plaintiff DOULAS MANER ("Plaintiff"), through their respective attorneys of record, Liebert Cassidy Whitmore and the Law Offices of Peter Sean Bradley, hereby stipulate and agree as follows: WHEREAS, counsel for Plaintiff served: • a Notice of Taking Deposition of Person Most Knowledgeable at the Coun
Summary: STIPULATION AND ORDER REGARDING EXTENSION FOR DISCOVERY CUTOFF MICHAEL J. SENG , Magistrate Judge . The parties hereto, Defendants COUNTY OF STANISLAUS and BIRGIT FLADAGER ("Defendants") and Plaintiff DOULAS MANER ("Plaintiff"), through their respective attorneys of record, Liebert Cassidy Whitmore and the Law Offices of Peter Sean Bradley, hereby stipulate and agree as follows: WHEREAS, counsel for Plaintiff served: • a Notice of Taking Deposition of Person Most Knowledgeable at the Count..
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STIPULATION AND ORDER REGARDING EXTENSION FOR DISCOVERY CUTOFF
MICHAEL J. SENG, Magistrate Judge.
The parties hereto, Defendants COUNTY OF STANISLAUS and BIRGIT FLADAGER ("Defendants") and Plaintiff DOULAS MANER ("Plaintiff"), through their respective attorneys of record, Liebert Cassidy Whitmore and the Law Offices of Peter Sean Bradley, hereby stipulate and agree as follows:
WHEREAS, counsel for Plaintiff served:
• a Notice of Taking Deposition of Person Most Knowledgeable at the County of Stanislaus with Production of Documents on or about September 10, 2015;
• a Re-Notice of Taking Deposition of Person Most Knowledgeable at the County of Stanislaus with Production of Documents on or about September 10, 2015, changing the date of the deposition; and
• an Amended Notice of Taking Deposition of Person Most Knowledgeable at the County of Stanislaus with Production of Documents on or about September 28, 2015, again changing the date of the deposition after meeting and conferring on availability.
WHEREAS, counsel for Defendants has met and conferred in good faith with counsel for Plaintiff regarding limiting the topic of the Person Most Knowledgeable deposition and the scope of the documents requested and the parties have been unable to resolve their dispute;
WHEREAS, counsel for Defendants, after providing notice to counsel for Plaintiff, requested a telephonic pre-motion conference with the Court for assistance in resolving the dispute and said conference will take place on or about October 5, 2015 at 4:00pm;
WHEREAS, after the telephonic pre-motion conference, Defendants may obtain permission from the Court to file a Motion to Quash the Deposition Notice or, in the alternative a Protective Order and cannot, by court order, file one before permission is granted;
WHEREAS, the non-expert discovery cutoff date in this case is October 23, 2015;
WHEREAS, Local Rule 251 requires any discovery motion to be filed at least 21 days before being heard, making October 2, 2015 the last day to file any discovery motions;
WHEREAS, in order to preserve Defendants' right to file a discovery motion regarding Plaintiff's Notice of Taking Deposition of Person Most Knowledgeable at the County of Stanislaus with Production of Documents after the telephonic pre-motion conference, the discovery cutoff date must be extended.
The parties hereby stipulate and agree to the following:
1. The Non-Expert Discovery Cutoff date is extended to October 28, 2015 only discovery related to Plaintiff's Notice of Taking Deposition of Person Most Knowledgeable at the County of Stanislaus with Production of Documents served on or about September 10, 2015, the re-notice served on or about September 10, 2015 and the amended notice, served on or about September 28, 2015.
2. All other non-expert discovery remains subject to the October 23, 2015 discovery cutoff date.
IT IS SO STIPULATED.
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
IT IS SO ORDERED.
