Williamsv.Miller

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIADec 5, 2012
Case No. 2:11-CV-01844-GEB-DAD (E.D. Cal. Dec. 5, 2012)

Case No. 2:11-CV-01844-GEB-DAD

12-05-2012

DIANA WILLIAMS, Plaintiff, v. PAMELA MILLER, in her individual capacity, and YOLO COUNTY DEPARTMENT OF EMPLOYMENT AND SOCIAL SERVICES Defendants.

CHARLETON S. PEARSE, SBN 122491 ADAM M. AMBROZY, SBN 258237 BENJAMIN D. ORAM, SBN 269453 LENAHAN, LEE, SLATER & PEARSE, LLP Attorneys for Defendants COUNTY OF YOLO DEPARTMENT OF EMPLOYMENT AND SOCIAL SERVICES and PAMELA MILLER MARY –ALICE COLEMAN, SBN 98365 THOMS B. GILL, SBN 146275 LAW OFFICE OF MARY-ALICE COLEMAN Attorneys for Plaintiff DIANA WILLIAMS


CHARLETON S. PEARSE, SBN 122491
ADAM M. AMBROZY, SBN 258237
BENJAMIN D. ORAM, SBN 269453
LENAHAN, LEE, SLATER & PEARSE, LLP

Attorneys for Defendants
COUNTY OF YOLO DEPARTMENT OF

EMPLOYMENT AND SOCIAL SERVICES and

PAMELA MILLER

MARY –ALICE COLEMAN, SBN 98365
THOMS B. GILL, SBN 146275
LAW OFFICE OF MARY-ALICE COLEMAN

Attorneys for Plaintiff
DIANA WILLIAMS


STIPULATION AND [PROPOSED]

ORDER REGARDING EXTENSION OF

TIME FOR PERCIPIENT WITNESS

DISCOVERY

All parties hereby stipulate to extending the closure date for percipient witness discovery to February 28, 2013. Both sides have been engaged in substantial electronic discovery resulting in production of over 56,000 e-mails, most of which are multiple pages in length. Hundreds of hours have been spent in just gathering, downloading and distributing these e-mails. The additional discovery time sought is for completion of numerous (9 at this point) depositions, with others thereafter. No other scheduling dates previously set will be altered by this stipulation and the resulting order, which the court is respectfully requested to grant.

In order to facilitate continuing discovery and evaluation of the case, Plaintiff DIANA WILLIAMS, (hereinafter referred to as "Plaintiff"), and Defendants, PAMELA MILLER AND COUNTY OF YOLO DEPARTMENT OF EMPLOYMENT AND SOCIAL SERVICES (hereinafter collectively referred to as "Defendants") hereby stipulate and seek an order of the Court modifying the Court's October 6, 2011 scheduling order as follows:

(1) All parties will complete percipient witness discovery on or before February 28, 2013.
(2) All other dates contained within the October 6, 2011 scheduling order or otherwise previously modified are to remain as ordered and are unmodified, altered, or changed.


This Stipulation may be executed in counter-part and faxed and/or authorized electronic signature shall be deemed the same as an original execution.

LENAHAN, LEE, SLATER & PEARSE, LLP

By: ___________________________


CHARLETON S. PEARSE


Attorneys for Defendant,


COUNTY OF YOLO and PAMELA MILLER


LAW OFFICE OF MARY-ALICE COLEMAN

By: ___________________________


THOMAS B. GILL


Attorneys for Plaintiff,


DIANA WILLIAMS


IT IS HEREBY ORDERED THAT:

(1) All parties will complete percipient witness discovery on or before February 28, 2013.
(2) All other dates contained within the October 6, 2011 scheduling order or otherwise previously modified are to remain as ordered and are unmodified, altered, or changed.


________________________


HON. GARLAND E. BURRELL, JR.


UNITED STATES DISTRICT JUDGE