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Associated General Contractors of America v. California Dep't of Transportation

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION


August 25, 2010

ASSOCIATED GENERAL CONTRACTORS OF AMERICA, SAN DIEGO CHAPTER, INC., A NONPROFIT CALIFORNIA CORPORATION, PLAINTIFF,
v.
CALIFORNIA DEPARTMENT OF TRANSPORTATION, ET AL., DEFENDANTS,
COALITION FOR ECONOMIC EQUITY AND NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SAN DIEGO CHAPTER, DEFENDANT-INTERVENORS.

The opinion of the court was delivered by: Judge: Hon. John A. Mendez

JOINT STIPULATION REGARDING DEPOSITIONS OF NON-PARTY WITNESSES AFTER THE CLOSE OF FACT DISCOVERY

WHEREAS, under the Court's August 18, 2010 Order, the deadline for fact discovery is September 3, 2010; and

WHEREAS, Defendant-Intervenors issued deposition subpoenas on non-parties Tom Holsman and Sam Hassoun of Associated General Contractors of California to appear for deposition on August 26, 2010 and August 30, 2010, respectively; and

WHEREAS, both Mr. Holsman and Mr. Hassoun are unavailable for deposition on the respective dates noticed for their depositions; and

WHEREAS, Defendant-Intervenors made reasonable efforts to secure the depositions of Mr. Holsman and Mr. Hassoun before the deadline for fact discovery;

WHEREAS, both Mr. Holsman and Mr. Hassoun are unable to schedule their depositions before September 3, 2010;

NOW, THEREFORE, Plaintiffs Associated General Contractors of America, San Diego Chapter, Inc.; Defendants California Department of Transportation (Caltrans), Cindy Kim, in her official capacity as Director of Caltrans, and Olivia Fonseca, individually, and in her official capacity as Deputy Director of Caltrans; and Defendant-Intervenors Coalition for Economic Equity, and the National Association for the Advancement of Colored People, San Diego Chapter (collectively, "the Parties") hereby stipulate and respectfully request that the Court approve that the depositions of Mr. Holsman and Mr. Hassoun occur after the deadline for fact discovery;

1. The deadline for fact discovery shall remain September 3, 2010.

2. Notwithstanding the aforementioned deadline, the depositions of non-parties Mr. Holsman and Mr. Hassoun may be rescheduled for September 8, 2010.

3. No party may object to the depositions of Mr. Holsman or Mr. Hassoun solely because they are scheduled after the deadline for fact discovery.

4. The allowance of fact discovery after the September 3, 2010 cut-off date is limited to the depositions of non-parties Mr. Holsman and Mr. Hassoun.

5. Nothing in this Stipulation and Order shall be construed as a waiver by the Parties of any objections they may make as to other discovery requests that call for fact-finding discovery to be completed beyond the factual discovery cut-off date of September 3, 2010.

6. Nothing in this Stipulation and Order shall be construed as a waiver by the Parties of their right, under Fed. R. Civ. P. 37, to move to compel discovery even if such motion is filed after the discovery cut-off date of September 3, 2010.

Ralph W. Kasarda Attorneys for Plaintiff SHARON L. BROWNE (SBN 119246) RALPH W. KASARDA (SBN 205286) Pacific Legal Foundation

DATED: August 24, 2010

G. Scott Emblidge Attorneys for Defendants RONALD W. BEALS THOMAS C. FELLENZ DANIEL A NEAR KATHRYN T. PAPALIA (SBN 173472) State of California Legal Department MARA E. ROSALES (SBN 104844) BENJAMIN SCHNAYERSON (SBN 257857) Rosales Law Partners LLP G. SCOTT EMBLIDGE (SBN 121613) RACHEL J. SATER (SBN 147976) Moscone, Emblidge & Quadra LLP

EVA JEFFERSON PATERSON (SBN 67081) SARA JACKSON (SBN 251915) Equal Justice Society

ALAN L. SCHLOSSER (SBN 49957) JORY C. STEELE (SBN 206944) American Civil Liberties Union Foundation of Northern California

IT IS SO ORDERED, this 25th day of August, 2010.

John A. Mendez United States District Judge

20100825

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