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Cruz v. United States Postal Service

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


March 9, 2009

CHRISTINA DE LA CRUZ, AN INDIVIDUAL; ISABEL DE LA CRUZ, AN INDIVIDUAL; AMY MICHELLE TARAZON BY AND THROUGH HER GUARDIAN AD LITEM, RICK TARAZON; JACOB PAUL DE LA CRUZ, BY AND THROUGH HIS GUARDIAN AD LITEM, ALFRED DE LA CRUZ, PLAINTIFFS,
v.
THE UNITED STATES POSTAL SERVICE; DAVINDER KAUR BADYAL, AN INDIVIDUAL; AND DOES 1 THROUGH 10, INCLUSIVE, DEFENDANTS.

The opinion of the court was delivered by: Dennis L. Beck United States Magistrate Judge

STIPULATION TO CONTINUE COMPLETION OF EXPERT DISCOVERY; ORDER RE SAME

Plaintiffs Christine De la Cruz, Isabel De la Cruz, Amy Michelle Tarazon and Jacob Paul De la Cruz ("plaintiffs") and defendant United States of America ("defendant") (collectively "the parties") stipulate, by and through the undersigned counsel, to continue this action's deadline by which to complete expert discovery approximately thirty (30) days, and as more specifically set forth below. Significantly, the parties at this time do not seek a continuance of the remaining components of this action's litigation schedule, including the currently set pretrial conference or trial dates.

The parties base this stipulation on good cause. To explain, counsel for the United States will be transferring from the civil division to the criminal division on Monday, March 16, 2009. His successor is expected to be arriving at the office on this same date, only one day before the closure of this action's current expert discovery deadline of Tuesday, March 17, 2009. Successor counsel will need sufficient time to analyze expert reports and relevant file documents to properly take and defend the two expert depositions pending in this case.

The parties therefore stipulate and agree to continue this action's deadlines as specified below, and base it on the above-stated good cause. The parties request the court to endorse this stipulation by way of formal order.

Old Date March 17, 2009

New Date April 17, 2009

Expert Discovery March 6, 2009

Dated: March 6, 2009

Respectfully submitted,

Law Offices of Federico Sayre McGREGOR W. SCOTT United States Attorney (As authorized, 3/6/09)

JAMES F. RUMM Attorney for Plaintiffs

BRIAN W. ENOS Attorneys for Defendant

IT IS SO ORDERED.

20090309

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