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Donald R. Rodriguez v. James E. Tilton

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


April 1, 2011

DONALD R. RODRIGUEZ,
PLAINTIFF,
v.
JAMES E. TILTON; MICHAEL C. GENEST;
JOHN CHIANG;
CLAUDE FINN;
LOUIS DEBARRAICUA, M.D.;
FILADELFO
VALASQUEZ OANDASAN JR., M.D.; SAMBRAJYA LAKSHMI PALAGUMMI,M.D AND DOES 1-100
DEFENDANTS

The opinion of the court was delivered by: Judge: Hon. Maxine M. Chesney

ADMINISTRATIVE MOTION AND STIPULATION FOR ORDER EXTENDING DISCOVERY CUT-OFF; Proposed ORDER

Date: Time:..9:00 a.m.

Place: Courtroom 7, 19th Floor

Case Filed: December 1, 2008

Trial Date: October 17, 2011

IT IS HEREBY STIPULATED by and between the parties to this action, by and through their respective counsel of record, as follows:

WHEREAS the deadline for completion of fact discovery is currently set for Wednesday, March 30, 2011.

WHEREAS Plaintiff Donald R. Rodriguez has been out of contact and, as a result, Plaintiff's counsel has been unable to comply with certain pending discovery requests, including the deposition of Plaintiff, which had been noticed for March 21, 2011.

WHEREAS Plaintiff's counsel has made and is making efforts to re-establish contact with the Plaintiff.

WHEREAS both sides believe that good cause exists to extend the discovery cut-off by days to provide Plaintiff's counsel sufficient time to establish contact with the Plaintiff and comply with Plaintiff's discovery obligations.

THEREFORE THE PARTIES HEREBY JOINTLY AND RESPECTFULLY HEREBY REQUEST that the Court extend the deadline for completion of fact discovery by 30 days, to April 29, 2011.

Respectfully submitted, DATED: March 29, 2011

COVINGTON & BURLING LLP

MATTHEW J. HAWKINSON Attorneys for Plaintiff

DONALD R. RODRIGUEZ

DATED: March 29, 2011

KAMALA D. HARRIS Attorney General for the State of California

TOM BLAKE Attorneys for Defendants

James E. Tilton; Michael C. Genest; John Chiang; Louis Debarraicua, M.D.; Filadelfo Valasquez Oandasan Jr., M.D.; Claude Finn; and Sambrajya Lakshmi Palagummi, M.D. completion

Good cause appearing, it is hereby ordered that the deadline for complete of fact discovery in this matter be continued until April 29, 2011. ,provided such continuance shall not, by itself, constitute good cause to continue any other deadline or date.

IT IS SO ORDERED.

MAXINE M. CHESNEY United States District Judge

20110401

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