US Equal Employment Opportunity Commission v. Hospital Housekeeping Systems of Houston, Inc.

Filing 19

Stipulation to extend Discovery Deadlines and ORDER, signed by Magistrate Judge Dennis L. Beck on 11/1/2012.(Discovery due by 3/1/2013; Designation of Expert Witnesses due by 3/21/2013; Disclosure of Supplemental Experts due by 4/21/2013) (Figueroa, O)

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1 2 3 4 5 6 Anna Y. Park, SBN 164242 Rumduol Vuong, SBN 264392 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 255 East Temple Street, Fourth Floor Los Angeles, CA 90012 Telephone: (213) 894-1108 Facsimile: (213) 894-1301 Attorneys for Plaintiff U.S. EEOC 7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 10 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, 11 12 13 14 15 16 17 Plaintiff, v. HOSPITAL HOUSEKEEPING SYSTEMS, INC., HOSPITAL HOUSKEEPING SYSTEMS, LLC, AND DOES 1-10, INCLUSIVE, Defendant(s). _____________________________________ ) Case No.: 1:11-CV-01658 LJO DLB ) ) STIPULATION TO EXTEND ) ) DISCOVERY DEADLINES ) ) ) ) ) ) ) ) ) ) 18 Plaintiff United States Equal Employment Opportunity Commission (“EEOC” or 19 “Plaintiff”) and Defendants Hospital Housekeeper Systems, Inc., Hospital Housekeeping 20 Systems LLC (“Defendants”), through their respective counsel of record, hereby stipulate 21 pursuant to Rules 16 and 26 of the Federal Rules of Civil Procedure as follows: 22 1. Good Cause to Extend Discovery Deadlines 23 All parties and counsel for all parties have engaged in good faith efforts to further 24 discovery in this case, including exchanging initial disclosures and engaging in written discovery 25 consisting of interrogatories, request for production of documents, and requests for admission. 26 However, there have been reasonable delays in providing responses to the written requests and 27 the scheduling of deposition of witnesses has been problematic as some witnesses have left 28 Defendants’ employment and other witnesses are currently outside the jurisdiction of this court. 1:11-CV-01549 LJO DLB -1- 1 Counsel for all parties have worked cooperatively in providing extensions to deadlines for the 2 purpose of adequately addressing the nature and scope of written discovery and to secure witness 3 testimony. However, due to other cases and commitments, it has proven difficult to hold the 4 necessary depositions and conduct necessary discovery prior to the end of the discovery deadline 5 contained in the original scheduling order. 6 The parties have also engaged in preliminary discussions regarding a settlement and 7 agree that given additional time to conduct the necessary discovery the parties should be in a 8 position to hold meaningful settlement discussions. 9 10 11 2. Stipulation to Extend Discovery Deadlines The parties stipulate that the original Joint Scheduling Order be amended to reflect the following new deadlines: 12 a. All discovery shall be completed before March 1, 2013. 13 b. The parties are directed to disclose all expert witnesses, in writing, on or 14 before March 21, 2013 and to disclose all supplemental experts on or before 15 April 21, 2013. 16 IT IS SO STIPULATED. 17 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 18 19 Date: November 1, 2012 By: 20 /s/ Rumie Vuong Rumie Vuong Attorney for Plaintiff U.S. EEOC 21 22 FULLBRIGHT JAWORSKI LLP 23 24 Date: November 1, 2012 By: 25 26 27 28 1:11-CV-01549 LJO DLB -2- /s/ Julie Capell Marcus Torrano Julie Capell Attorney for Defendants Hospital Housekeeping Inc and Hospital Housekeeping LLC 1 ORDER 2 FOR GOOD CAUSE SHOWN, this Stipulation to extend Discovery deadlines is hereby 3 4 5 approved and the new deadlines for discovery as set forth in Section III of the Joint Scheduling Order shall be amended as follows: The parties are ordered to complete all discovery on or before March 1, 2013. 6 The parties are directed to disclose all expert witnesses, in writing, on or before March 7 8 9 10 21, 2013 and to disclose all supplemental experts on or before April 21, 2013. The written designation of retained and non retained experts shall be made pursuant to Fed. R.Civ.P. Rule 26(a)(2), (A) and (B) and shall include all information required thereunder. All other provisions of Part III of the Joint Scheduling Conference Order shall otherwise 11 12 remain in effect. 13 IT IS SO ORDERED. 14 Dated: 15 /s/ Dennis November 1, 2012 L. Beck UNITED STATES MAGISTRATE JUDGE 16 DEAC_Signature-END: 17 3b142a 18 19 20 21 22 23 24 25 26 27 28 1:11-CV-01549 LJO DLB -3-

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