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Donald R. Rodriguez v. James E. Tilton

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 ...


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