Corona v. Knowles et al

Filing 99

STIPULATION Regarding Scheduling Order, signed by District Judge Lawrence J. O'Neill on 10/6/11: Non-Expert Discovery due by 3/1/2012. Expert Discovery due by 5/3/2012. Non-Dispositive Motions filed by 5/15/2012. Dispositive Motions filed by 6/2 9/2012. Settlement Conference - Parties to contact Magistrate. Pretrial Conference set for 10/15/2012 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill. Trial (JT-5 days) set for 12/10/2012 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill(Hellings, J)

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BINGHAM MCCUTCHEN LLP
WARREN E. GEORGE (SBN 53588)
MANU PRADHAN (SBN 253026)
Three Embarcadero Center
San Francisco, CA 94111-4067
Telephone: [phone]
Facsimile: 415.393.2286
[e-mail]
[e-mail]
Attorneys for Plaintiffs Maria del Rosario
Corona and Andres Santana

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARIA DEL ROSARIO CORONA, AS HEIR
OF THE ESTATE OF OSCAR CRUZ, et. al.,

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Plaintiffs,
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Case No. 1:08-CV-00237-LJO-DLB
STIPULATION REGARDING
SCHEDULING ORDER; ORDER

v.
KELLY HARRINGTON, et al.,

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Defendants.

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING SCHEDULING ORDER; [PROPOSED] ORDER
A/74535557.1

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STIPULATION

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Pursuant to Fed. R. Civ. Proc. 16(b)(4), the parties stipulate to an extension of the

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deadlines in the Scheduling Order issued on June 30, 2011 (Docket Item # 97).

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Defendants require additional time to complete their document production. Declaration

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Of Manu Pradhan In Support Of Stipulation Regarding Scheduling Order (“Pradhan Decl.”), ¶¶

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3-4. Progress has also been delayed because the parties are negotiating a Protective Order to

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facilitate the production of documents Defendants will not otherwise produce based on their

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claims of confidentiality. Pradhan Decl., ¶ 5. Other discovery issues have arisen that are

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delaying the case, and though the parties are continuing to meet and confer regarding those

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issues, some motion practice is likely. Pradhan Decl., ¶ 4.

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The parties have discussed how these issues affect the case schedule. Pradhan Decl., ¶¶

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6-7. Subject to the availability of the Court, the parties jointly request that the Court amend the

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Scheduling Order to reflect the following dates:

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Event

Current Date

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New Dates Ordered By
Court

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Filing of Stipulation or
Motions Amending Pleadings

October 7, 2011

January 5, 2012

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Settlement Conference

November 30, 2011,
10:00 a.m., Courtroom 9

Parties to contact Magistrate

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Judge for acceptable date.

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Non- Expert Discovery

December 2, 2011

March 1, 2012

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Expert Discovery

February 3, 2012

May 3, 2012

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February 15, 2012

May 15, 2012

March 9, 2012

June 7, 2012

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Filing of Non-Dispositive
Motion:
Hearing re Non-Dispositive
Motion

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Filing of Dispositive Motion:

April 20, 2012

June 29, 2012

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Hearing re Dispositive
Motion

June 5, 2012

August 15, 2012

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING SCHEDULING ORDER; [PROPOSED] ORDER
A/74535557.1

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Event

Current Date

New Dates Ordered By

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Court
Pre-Trial Conference

July 17, 2012, 8:30 a.m.,
Courtroom 4

October 15, 2012 at 8:30 a.m.

Trial

September 10, 2012,
8:30 a.m., Courtroom 4 JT 5
days

December 10, 2012 at 8:30

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a.m.

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DATE: October 6, 2011

BINGHAM MCCUTCHEN LLP

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By:

/s/
Manu Pradhan
Attorneys for Plaintiffs

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DATE: October 6, 2011

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ATTORNEY GENERAL OF THE STATE OF
CALIFORNIA

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By:

/s/
Kelli M. Hammond
Attorney for Defendants

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING SCHEDULING ORDER; [PROPOSED] ORDER
A/74535557.1

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING SCHEDULING ORDER; [PROPOSED] ORDER
A/74535557.1

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ORDER

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GOOD CAUSE showing, the dates are modified as reflected above and with dates in bold

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different than those requested by the parties’ stipulation.

IT IS SO ORDERED.

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Dated:

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/s/ Lawrence J. O’Neill

October 6, 2011

UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING SCHEDULING ORDER; [PROPOSED] ORDER
A/74535557.1