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

Filing 28

STIPULATION to Extend Discovery and Dispositive Motion Deadlines; ORDER signed by District Judge Lawrence J. O'Neill on 3/13/13. Non Expert Discovery Deadline: 4/18/2013, Plaintiff's Opposition to Defendants' Motion for Summa ry Judgment Deadline: 4/18/2013, Expert Designation Deadline: 4/22/2013, Expert Discovery Deadline: 5/22/2013, Settlement Conference set for 3/28/2013 at 09:30 AM in Courtroom 8 (BAM) before Magistrate Judge Barbara A. McAuliffe; Pretrial Conference set for 6/5/2013 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill. (Verduzco, M)

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Anna Y. Park, CA SBN 164242
Rumduol Vuong, CA SBN 264392
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
255 East Temple Street, Fourth Floor
Los Angeles, CA 90012
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorney for Plaintiff
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
UNITED STATES DISTRICT COURT
EATERN DISTRICT OF CALIFORNIA

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,

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Plaintiff,

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vs.
HOSPITAL HOUSKEEPING SYSTEMS,
LTD., HOSPITAL HOUSEKEEPING
SYSTEMS OF HOUSTON, INC,
HOSPITAL HOUSEKEEPING SYSTEMS,
INC., HOSPITAL HOUSKEEPING
SYSTEMS, LLC, AND DOES 1-10,
INCLUSIVE,

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Defendant(s).

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Case No.: 1:11-CV-1658 LJO SAB
STIPULATION TO EXTEND
DISCOVERY AND DISPOSITIVE
MOTION DEADLINES

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A. Good Cause to Extend Discovery and Motion Deadlines

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Plaintiff United States Equal Employment Opportunity Commission (“EEOC” or

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“Plaintiff”) and Defendants Hospital Housekeeping Systems Inc. and Hospital Housekeeping

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Systems, LLC (“Defendants”), through their respective counsel of record herein, hereby

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respectfully request continuances of the non-expert and expert discovery cutoff dates, expert

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disclosure deadlines, deadlines to oppose and reply to the dispositive motions, and the pretrial

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conference date.

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The parties have dutifully engaged in factual discovery during this litigation, including

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exchanging initial disclosures, preparing and responding to several sets of written discovery

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requests, and taking witness depositions. Both parties have several depositions and discovery

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requests pending. Non-expert discovery is due to be completed on March 25, 2013. Counsel for

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both parties engaged in active settlement discussions, including several conference calls and an

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in person meeting. The parties are of the good faith belief that a settlement conference in front

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of a magistrate judge will resolve the outstanding issues preventing a successful settlement. The

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parties have conferred with the court and agreed to a settlement conference on March 28, 2013 at

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9:30AM in front of Magistrate Judge Barbara A. McAuliffe.

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Defendants have filed a motion for summary judgment, whose opposition is currently due

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on March 28, 2013 with Defendants’ reply due on April 4, 2013. The parties thereby request an

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extension of the current litigation deadlines to focus on settling this case with the court’s

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assistance.

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B. Stipulation to Extend Deadlines

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The parties stipulate that the Scheduling Order be amended to reflect the following new

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deadlines:
1. The parties shall attend a settlement conference before Judge Barbara A. McAuliffe

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on March 28, 2013 at 9:30AM. Confidential settlement conference briefs shall be

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sent to Judge McAuliffe’s chambers on or before March 21, 2013.

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2. All non expert discovery shall be completed on or before April 18, 2013.

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3. Plaintiff’s opposition to Defendants’ motion for summary judgment shall be filed on

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or before April 18, 2013. Defendants’ reply to Plaintiff’s opposition shall be filed on

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or before April 25, 2013. Unless the Court orders otherwise, there shall be no hearing

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set for the motion for summary judgment, and a ruling will be made on the papers.

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4. Expert designations shall be made on or before April 22, 2013 and rebuttal expert
designations shall be made on or before May 6, 2013.
5. All expert discovery shall be completed on or before May 22, 2013.

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6. The pre-trial conference shall be held on June 5, 2013 at 8:30AM. The joint pre-trial
conference statement shall be due on or before May 29, 2013.

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IT IS SO STIPULATED.
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

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Date: March 13, 2013

By:

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/s/ Rumie Vuong
Rumie Vuong
Attorney for Plaintiff U.S. EEOC

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FULLBRIGHT & JAWORSKI LLP

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Date: March 13, 2013

By:

/s/ Julie Capell
Julie M. Capell
Attorney for Defendants Hospital Housekeeping
Systems Inc. and Hospital Housekeeping Systems,
LLC

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ORDER

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For good cause shown, the stipulation to extend discovery deadlines is hereby approved

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and the new deadlines for discovery as set forth in the Scheduling Order shall be amended as

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follows:

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1. The parties shall attend a settlement conference before Judge Barbara A. McAuliffe

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on March 28, 2013 at 9:30AM. Confidential settlement conference briefs shall be

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sent to Judge McAuliffe’s chambers on or before March 21, 2013.

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2. All non expert discovery shall be completed on or before April 18, 2013.

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3. Plaintiff’s opposition to Defendants’ motion for summary judgment shall be filed on

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or before April 18, 2013. Defendants’ reply to Plaintiff’s opposition shall be filed on

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or before April 25, 2013. Unless the Court orders otherwise, there shall be no hearing

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set for the motion for summary judgment, and a ruling will be made on the papers.

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4. Expert designations shall be made on or before April 22, 2013 and rebuttal expert

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designations shall be made on or before May 6, 2013.

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5. All expert discovery shall be completed on or before May 22, 2013.

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6. The pre-trial conference shall be held on June 5, 2013 at 8:30AM. The joint pre-trial

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conference statement shall be due on or before May 29, 2013.

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All other provisions of the Scheduling Conference Order shall otherwise remain in effect.

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IT IS SO ORDERED.
Dated:

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/s/ Lawrence J. O’Neill

March 13, 2013

UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:

66h44d

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