Opinion
CASE NO. 2:10-CV-03246-MCE
07-05-2012
HANSON BRIDGETT LLP WILLIAM D. TAYLOR, SBN51689 JOHN W. KLOTSCHE, SBN257992 Attorneys for Defendant and Cross- Complainant HAMSTRA BUILDERS, INC.
HANSON BRIDGETT LLP
WILLIAM D. TAYLOR, SBN51689
JOHN W. KLOTSCHE, SBN257992
Attorneys for Defendant and Cross
Complainant HAMSTRA BUILDERS, INC.
STIPULATION FOR THE RULE 30(b)(6)
DEPOSITION OF HAMSTRA BUILDERS
It is hereby stipulated and agreed, by and between the parties hereto through their counsel of record, that pursuant to Fed.R.Civ. P. 30(b)(6) Hamstra Builders agrees to produce a representative for video deposition on July 13, 2012 at the office of Hamstra Builders, located at 12028 N. 200 W. Wheatfield, Indiana 46392-9615. Although July 13, 2012 falls four days outside of the deadline for non-expert discovery previously set by the Court, the parties agree to allow this deposition to occur following the close of non-expert discovery. Should Hamstra Builders fail to produce a representative on July 13, 2012 (or such other date on which the parties mutually agree), Plaintiff shall be entitled to file a motion to compel, and request therein the relief it deems appropriate, notwithstanding the fact that the non-expert discovery period will have closed. Plaintiff will not be required to meet and confer prior to filing the motion. Additionally, Hamstra Builders shall have the right to contest and file an appropriate response to any such motion.
FREEBORN & PETERS LLP
By __________
MEGHAN TEPAS
Attorneys for Defendant/Cross-Plaintiff
Hamstra Builders, Inc.
MAIRE & BURGESS
IT IS SO ORDERED:
By: __________
CLINT BOREN
Attorneys for Plaintiff/Cross-Defendant
Western Resource Partners, Inc.
______________
MORRISON C. ENGLAND, JR
UNITED STATES DISTRICT JUDGE