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Equal Employment Opportunity Commission v. Wal-Mart Stores

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


March 13, 2013

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, PLAINTIFF,
v.
WAL-MART STORES, INC., 24 DEFENDANT.

The opinion of the court was delivered by: Hon. John A. Mendez United States District Court Judge

STIPULATION AND ORDER EXTENDING FACT DISCOVERY

DEADLINE Complaint Filed: December 15, 2011

STIPULATION AND [PROPOSED] ORDER EXTENDING FACT DISCOVERY

DEADLINE CASE NO. 11-CV-03327-JAM-CKD

Plaintiff U.S. Equal Employment Opportunity Commission ("EEOC") and Defendant Wal-Mart Stores, Inc. ("Defendant") (collectively, the "Parties") hereby stipulate, by and through 3 their respective counsel, as follows: 4

WHEREAS, the Court's November 28, 2012 Order ("Order") for this matter set various 5 procedural deadlines and dates including setting the deadline for fact discovery to March 15, 6 2013; 7

WHEREAS, the EEOC propounded certain document requests, seeking production prior 8 to the March 15, 2013 fact discovery deadline; 9

WHEREAS, the Parties met and conferred in good faith regarding certain of the EECO's 10 document requests and have reached an agreement regarding the scope of documents to be 11 produced by Defendant; 12

WHEREAS, Defendant has notified the EEOC that Defendant is diligently working to 13 produce the agreed upon documents but will not be able to complete its production by the March 14 15, 2013 fact discovery deadline; 15

WHEREAS, the EEOC noticed the deposition of Wal-Mart employee Ben Souza to be 16 held prior to the March 15, 2013 fact discovery deadline; 17

WHEREAS, the Parties met and conferred in good faith to reschedule Mr. Souza's 18 deposition for March 18, 2013, three days after the March 15, 2013 fact discovery deadline;

THEREFORE, the Parties stipulate to continue the deadline for fact discovery, by a period 2 of three weeks, from March 15, 2013 to April 5, 2013; we request that no other dates or deadlines 3 be changed. 4

IT IS SO STIPULATED.

Dated: March 13, 2013 MORGAN, LEWIS & BOCKIUS LLP 7 8 By: /s/ L. Julius M. Turman L. JULIUS M. TURMAN 9 PHILIP J. SMITH Attorneys for Defendant 10 WAL-MART STORES, INC. 11 Dated: March 13, 2013 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 12 13 By /s/ David F. Offen-Brown 14 DAVID F. OFFEN-BROWN Attorneys for Plaintiff EEOC

IT IS SO ORDERED.

John A. Mendez

20130313

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