The opinion of the court was delivered by: John A. Mendez U. S. District Court Judge
DAN SIEGEL, SBN 56400 PETER HABERFELD, SBN 41723 SIEGEL & YEE 499 14th Street, Suite 220 Oakland, CA 94612 Telephone: (510) 839-1200 Facsimile: (510) 444-6698 Attorneys for Plaintiffs JERALD CLINTON (J.C.) EAGLESMITH, RAMONA EAGLESMITH, EILEEN COX, and BRUCE BARNES
STIPULATION AND ORDER TO TAKE THE DEPOSITION
ON JIM LAKE ON JUNE 7, OR JUNE 11, 2012
Plaintiffs J.C. Eaglesmith, Ramona Eaglesmith, Bruce Barnes and Eilleen Cox, and defendants Plumas County Office of Education/Plumas Unified School District, Sue Segura, and Jeff Ray, by and through their attorneys of record, hereby stipulate as follows:
1. On May 22, 2012, the Court issued an Order (Dkt. No. 103) allowing plaintiffs to take the deposition of Jim Lake, Principal at Greenville Junior/Senior High School in Plumas County Unified School District, and that they be allowed to take his deposition in lieu of the deposition of Brad Baker. The parties had Eaglesmith v. Ray, Case No. 2:11-cv-00098-JAM-JFM Stipulation and Order to Depose Jim Lake on June 7 or June 11, 2012 - 1 ted with pdfFactory trial version www.pdffactory.com scheduled the deposition of Mr. Baker for Thursday, May 31, 2012 in Sacramento, California at 1:00 PM.
2. On Tuesday, May 29, 2012, defendants' counsel communicated to plaintiffs' counsel Mr. Lake's proposal that, for his convenience, his deposition be scheduled to either June 7 at 1:00 PM or June 11 at 10:00 AM or later in Sacramento. On May 30, 2012, defendants' counsel wrote to plaintiffs' counsel that Mr. Lake is unavailable on May 31, 2012.
3. The Court's Status (Pre-trial Scheduling) Order (Dkt. No. 19) states "all discovery shall be completed by June 1, 2012. In this context, 'completed' means that all discovery shall have been conducted so that all depositions have been taken .."
4. The parties agree to schedule the deposition of Mr. Lake on either of the two dates proposed by Mr. Lake.
5. The parties agree to waive the discovery cut-off as it pertains only to this deposition for the purpose of the convenience of Mr. Lake. The cut-off would be waived for no other purpose.
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