The opinion of the court was delivered by: Hon. Edward M. Chen
JOINT STIPULATION AND [PROPOSED] ORDER STAYING OBLIGATION UNDER SUBPOENA PENDING DISPOSITION OF PLAINTIFF'S MOTION TO QUASH
Plaintiff Alicia Harris ("Plaintiff") and defendant, Vector Marketing Corp. ("Defendant"), by and through their counsel of record, hereby stipulate and agree as follows:
WHEREAS, Defendant served subpoenas upon Pasadena High School, CIS Academy, Pasadena City College, and John Muir High School seeking production of records relating to Plaintiff's academic performance and evaluations, transcript of grades and course enrollment, dates of enrollment, attendance, any academic diagnostic examinations and examination scores, and any education, academic proficiency, or other related testing administed to Plaintiff.
WHEREAS, Plaintiff intends to promptly file a Motion to Quash said subpoenas.
WHEREAS, the filing of a Motion to Quash does not stay obligations of recipients to comply with their obligations under a subpoena.
WHEREAS, the Court's disposition of Plaintiff's Motion to Quash could affect the parties' obligations under the subpoena.
WHEREAS, Plaintiff's counsel and Defendant's counsel believes it is in their mutual best interests to stay Pasadena High School, CIS academy, Pasadena City College, and John Muir High School's obligations pursuant to the subpoena, for a period of time not to exceed forty-five days from the date of the entry of the proposed order herein.
NOW THEREFORE, IT IS HEREBY STIPULATED by the parties herein, through their counsel of record, as follows:
(1) The date for production of the documents requested in the subpoenas to Pasadena High School, CIS academy, Pasadena City College, and John Muir High School shall be stayed pending the Court's disposition of Plaintiff's Motion to Quash, for a period of time not to exceed forty-five days from the date of the entry of the proposed order herein. The Parties will notify the recipients of the subpoenas immediately following the Court's issuance of its Order on the Motion to Quash, as to whether compliance is still required, and if so, on what date compliance is to be completed;
(2) Plaintiff will file her motion to quash on or before June 4, 2010.
MARLIN & SALTZMAN Christina A. Humphrey, Esq. Attorneys for Plaintiff
REED SMITH, LLP Roxanne M. Wilson, Esq. Attorneys ...