The opinion of the court was delivered by: Kendall J. Newman United States Magistrate Judge
JAMES J. BANKS (SBN 119525) ROBERTA LINDSEY SCOTT (SBN 117023) BANKS & WATSON Hall of Justice Building 813 6th Street, Suite 400 Sacramento, CA 95814-2403 Telephone: (916) 325-1000 Facsimile: (916) 325-1004 Email: email@example.com Email: firstname.lastname@example.org Attorneys for Defendant, LARRY W. HARMON
STIPULATION AND [PROPOSED] ORDER
RE ORDER FOR APPEARANCE AND EXAMINATION OF JUDGMENT DEBTOR LARRY W. HARMON DATE: January 10, 2011 TIME: 9:00 A.M. COURTROOM: 25
WHEREAS, on or about December 15, 2010, this Court ordered that judgment debtor, Larry W. Harmon, appear personally on Monday, January 10, 2011, at 9:00 A.M., in Courtroom 25 of the United States District Courthouse, to answer questions regarding his real and personal property; and
WHEREAS, Mr. Harmon has a childcare conflict on that date, which conflict has been called to the attention of plaintiffs' and creditors' counsel, Mr. Stephen H. Turner; and
WHEREAS, plaintiffs and creditors and Mr. Harmon are meeting and conferring regarding a production of documents in advance of the debtor's examination to permit Mr. Turner sufficient time to review documents to permit him to conduct a meaningful examination.
WHEREAS, today Mr. Harmon's counsel, James J. Banks, contacted Mr. Turner to inquire about a continuance of the appearance and examination to January 28, 2011, a date on which Mr. Harmon is available. Counsel met and conferred about that issue. Mr. Turner subsequently advised that plaintiffs and creditors will so stipulate provided: (1) there are no further continuances of the examination; and (2) Mr. Harmon will produce non-privileged responsive documents at least two business days in advance of the continued examination date (subject to Mr. Harmon's objections to the plaintiffs' and creditors' subpoena therefor). Mr. Banks communicated Mr. Harmon's agreement to those conditions.
WHEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE AS FOLLOWS:
The date of Mr. Harmon's examination as previously ordered by this Court shall be continued from January 10, 2011 to January 28, 2011. The time and location of the examination shall remain the same.
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