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
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
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
MATTHEW J. HAWKINSON Attorneys for ...