Filed: Jun. 13, 2019
Latest Update: Jun. 13, 2019
Summary: STIPULATION TO CONTINUE DISCOVERY CUTOFF (First Request) CAM FERENBACH , Magistrate Judge . IT IS HEREBY STIPULATED between Plaintiff JONNAH GARCIA ("Plaintiff") and Defendant NATIONAL RECOVERIES, INC. ("Defendant"), through their respective counsel, as follows: WHEREAS, on February 8, 2019, a Proposed Discovery Plan and Scheduling Order pursuant to stipulation of the parties (see ECF No. 18); WHEREAS, the currently set dates and deadlines are as follows: June 26, 2019: Close of discove
Summary: STIPULATION TO CONTINUE DISCOVERY CUTOFF (First Request) CAM FERENBACH , Magistrate Judge . IT IS HEREBY STIPULATED between Plaintiff JONNAH GARCIA ("Plaintiff") and Defendant NATIONAL RECOVERIES, INC. ("Defendant"), through their respective counsel, as follows: WHEREAS, on February 8, 2019, a Proposed Discovery Plan and Scheduling Order pursuant to stipulation of the parties (see ECF No. 18); WHEREAS, the currently set dates and deadlines are as follows: June 26, 2019: Close of discover..
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STIPULATION TO CONTINUE DISCOVERY CUTOFF (First Request)
CAM FERENBACH, Magistrate Judge.
IT IS HEREBY STIPULATED between Plaintiff JONNAH GARCIA ("Plaintiff") and Defendant NATIONAL RECOVERIES, INC. ("Defendant"), through their respective counsel, as follows:
WHEREAS, on February 8, 2019, a Proposed Discovery Plan and Scheduling Order pursuant to stipulation of the parties (see ECF No. 18);
WHEREAS, the currently set dates and deadlines are as follows:
June 26, 2019: Close of discovery
WHEREAS, Plaintiff noticed the Deposition of Defendant, for June 17, 2019 and Defendant has noticed the deposition of Plaintiff for June 25, 2019.
WHEREAS, the June 17, 2019 deposition date did not work for Defendant, given the unavailability of counsel for Defendant.
WHEREAS, the following is a summary of the discovery completed and to be completed:
(a) Discovery completed: Plaintiff has propounded and Defendant has responded to written discovery requests.
(b) Discovery that remains to be completed: depositions of Plaintiff and Defendant.
(c) The parties have been working to try to resolve the case. Plaintiff and Defendant have each noticed the depositions for completion before the discovery cutoff; however, an unanticipated scheduling conflict will prevent the depositions from being completed before the discovery cutoff.
(d) The parties propose that the discovery cutoff be continued through and until August 1, 2019 for the limited purpose of completing the depositions of Plaintiff and Defendant.
Based on the foregoing it is stipulated and agreed that the June 26, 2019 discovery cutoff be continued to August 1, 2019 for the limited purpose of completing the depositions of Plaintiff and Defendant. This is the first stipulation for extension of discovery deadlines in this case.
A [Proposed] Order regarding this stipulation is submitted concurrently herewith for the Court's consideration.
IT IS SO STIPULATED.
ORDER
The Court, having reviewed the STIPULATION TO CONTINUE DISCOVERY CUTOFF (First Request), good cause appearing, orders as follows:
The June 26, 2019 discovery cutoff is continued to August 1, 2019 for the limited purpose of completing the depositions of Plaintiff and Defendant.
