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Terry Sandres, An Individual v. Corrections Corporation of America

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION


April 13, 2011

TERRY SANDRES, AN INDIVIDUAL,
PLAINTIFF,
v.
CORRECTIONS CORPORATION OF AMERICA, A MARYLAND CORPORATION; AND DOES 1 THROUGH 50, INCLUSIVE,
DEFENDANTS.

The opinion of the court was delivered by: Magistrate Judge: Hon. Jennifer L. Thurston

Barry M. Appell, Esq. State Bar No.: 174324 APPELL HILAIRE BERNARDO LLP 15233 Ventura Blvd., Suite 420 Sherman Oaks, CA 91403 (818) 788-2300 Fax: (818) 788-2464 E-Mail: barry@ahblegal.com Attorney for Plaintiff, Terry Sandres PAUL M. GLEASON State Bar No.: 155569 RICHARD Y. CHEN State Bar No.: 225392 KATHY H. GAO State Bar No.: 259019 GLEASON & FAVAROTE, LLP 800 West Sixth Street, Suite 1010 Los Angeles, California 90017 Telephone: (213) 452-0510 Facsimile: (213) 452-0514 pgleason@gleasonfavarote.com rchen@gleasonfavarote.com kgao@gleasonfavarote.com Attorneys for Defendants Corrections Corporation of America and CCA of Tennessee, LLC

STIPULATION AND ORDER TO EXTEND THE FILING DEADLINE AND HEARING DATE FOR MOTIONS TO COMPEL ON CERTAIN DISCOVERY DISPUTES

Action Filed: July 24, 2009

Trial Date: August 30, 2011

THE PARTIES TO THE ABOVE-CAPTIONED MATTER, by and through their respective attorneys of record, hereby enter into this stipulation to extend the deadline and hearing date for motions to compel on certain discovery disputes detailed below based on the following: WHEREAS, the deadline to file non-dispositive pre-trial motions is April 15, 2011 (Declaration of Kathy H. Gao ("Gao Decl."), ¶ 2); and WHEREAS, at issue now are written discovery requests defendants Corrections Corporation of America ("Corrections Corp.") and CCA of Tennessee, LLC ("CCA") (hereinafter collectively referred to as "Defendants") served on plaintiff Terry Sandres ("Plaintiff") which include the following:

(a) CCA's Third Set of Requests for Production of Documents (Nos. 50-51);

(b) CCA's Second Set of Requests for Admissions (Nos. 6-7);

(c) CCA's Second Set of Special Interrogatories (Nos. 17-19);

(d) CCA's Third Set of Special Interrogatories (No. 20);

(e) Corrections Corp.'s Second Set of Special Interrogatories (Nos. 17-24);

(hereinafter collectively referred to as the "Discovery Requests") (Gao Decl., ¶ 3); and

WHEREAS, Plaintiff has served responses to the Discovery Requests (Gao Decl., ¶ 4); and

WHEREAS, on March 25, 2011, Defendants' counsel sent Plaintiff's counsel a meet and confer letter regarding Plaintiff's responses to the Discovery Requests and called for Plaintiff to provide supplemental responses thereto no later than April 1, 2011 (Gao Decl., ¶ 5); and

WHEREAS, on March 31, 2011, Plaintiff's counsel responded to Defendants' counsel's March 25, 2011 meet and confer letter and indicated that Plaintiff would not be able to provide supplemental discovery responses until the week of April 11, 2011, at the earliest, due to a prepaid vacation from April 2-9, 2011 (Gao Decl., ¶ 6); and

WHEREAS, the parties have scheduled private mediation for April 14, 2011 (Gao Decl., ¶ 7); and

WHEREAS, the parties have continued to diligently meet and confer on these outstanding discovery disputes (Gao Decl., ¶ 8); and

WHEREAS, to allow the parties additional time to meet and confer on the pending discovery issues and participate in private mediation, as well as to avoid burdening the court with unnecessary discovery motions, the parties believe that it is in their best interest, as well as in the preservation of their financial resources, that the deadline to file any necessary motions to compel concerning the Discovery Requests -- limited to the issues specifically identified in Defendants' March 25, 2011 meet and confer correspondence -- be continued to April 29, 2011, and the date to have such motions heard by the Court be continued to June 10, 2011 (Gao Decl., ¶ 9).

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED and requested by the parties through their respective attorneys of record that this Court order as follows:

1. That the deadline to file any necessary motions to compel concerning the Discovery Requests -- limited to the issues specifically identified in Defendants' March 25, 2011 meet and confer correspondence -- is continued to April 29, 2011; and

2. That the date to have any necessary motions to compel concerning the Discovery Requests -- limited to the issues specifically identified in Defendants' March 25, 2011 meet and confer correspondence -- heard by the Court is continued to June 10, 2011.

IT IS SO STIPULATED.

IT IS SO ORDERED.

Jennifer L. Thurston UNITED STATES MAGISTRATE JUDGE

20110413

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