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Sanchez v. County of Sacramento

United States District Court, E.D. California, Sacramento Division

January 15, 2020

CRYSTAL R. SANCHEZ, Plaintiff,
v.
COUNTY OF SACRAMENTO, et al., Defendants.

          Mark E. Merin Paul H. Masuhara LAW OFFICE OF MARK E. MERIN Attorneys for Plaintiff CRYSTAL R. SANCHEZ

          PLAINTIFF'S REQUEST FOR LEAVE TO FILE OVERSIZED JOINT STATEMENT RE: DISCOVERY DISAGREEMENT; [PROPOSED] ORDER

          ALLISON CLAIRE UNITED STATES MAGISTRATE JUDGE

         I. INTRODUCTION

         Plaintiff Crystal R. Sanchez requests leave of Court to file an oversized Joint Statement Re: Discovery Dispute in connection with the pending motions to compel and for expenses (ECF No. 13).

         II. REQUEST

         On January 15, 2019, Plaintiff Crystal R. Sanchez (“Plaintiff”) filed motions to compel and for expenses before the Court. (ECF No. 13.) The grounds for Plaintiff's motions, including substantive argument and supporting declarations and exhibits, will be submitted with and attached to a forthcoming Joint Statement Re: Discovery Disagreement, pursuant to E.D. Cal. L.R. 251(c).

         Local Rules require that a Joint Statement “specify with particularity the following matters: (1) The details of the conference or conferences; (2) A statement of the nature of the action and its factual disputes insofar as they are pertinent to the matters to be decided and the issues to be determined at the hearing; and (3) The contentions of each party as to each contested issue, including a memorandum of each party's respective arguments concerning the issues in dispute and the legal authorities in support thereof.” E.D. Cal. L.R. 251(c). Further, “[e]ach specific … item objected to … and the objection thereto, shall be reproduced in full” in the Joint Statement. Id.

         Pursuant to this Court's Standing Order concerning discovery disputes, “[a]bsent leave of court for good cause shown, the Joint Statement is limited to 25 pages, exclusive of exhibits and tables (if any).” (See <www.caed.uscourts.gov/caednew/assets/File/Judge Claire Standing Orders.pdf> [Standing Order] at 2.)

         “Good cause” exists for the Court to grant leave to file an oversized Joint Statement in connection with Plaintiff's pending motions in this case (ECF No. 13). Specifically, Plaintiff's pending motions address objections by Defendant County of Sacramento (“County”) to thirty-six (36) individual requests for production. In response to each of those thirty-six (36) individual requests, Defendant County objected and failed to produce one-single document. Defendant County asserted boilerplate responses and objections to nearly every request. For example, Defendant County asserted numerous boilerplate objections in response to nearly every one of Plaintiff's thirty-six (36) individual requests. As a result, Plaintiff's mere compliance with E.D. Cal. L.R. 251(c)'s requirement that “[e]ach specific … item objected to … and the objection thereto, [] be reproduced in full, ” alone, would consume more pages than the 25-page limit permitted by the Court's Standing Order.

         Therefore, leave to file an oversized Joint Statement is necessary to permit the parties to comply with E.D. Cal. L.R. 251(c)'s requirement that the parties address “with particularity” (1) “The details of the conference or conferences”; (2) “A statement of the nature of the action and its factual disputes”; and (3) “The contentions of each party as to each contested issue, including a memorandum of each party's respective arguments concerning the issues in dispute and the legal authorities in support thereof.” Plaintiff suggests-without precisely knowing the extent of Defendant County's yet-to-be-developed argument in opposition-that an increased page-limit of fifty (50) pages would be appropriate in this instance. However, this estimate is contingent upon the subsequent development of the argument to be contained in the Joint Statement.

         III. CONCLUSION

         For the reasons stated, Plaintiff Crystal R. Sanchez respectfully requests leave of Court to file an oversized Joint Statement Re: Discovery Dispute of fifty (50) pages in connection with the pending motions to compel and for sanctions (ECF No. 13).

         [PROPOSED] ORDER

         GOOD CAUSE shown, the Court GRANTS Plaintiff Crystal R. Sanchez's request for leave to file an oversized Joint Statement Re: Discovery Dispute in connection with the pending motions to compel and for sanctions (ECF No. 13). The Court ...


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