Ceja-Corona v. CVS Pharmacy, Inc.

Filing 38

Joint Stipulation to continue all deadlines; ORDER, signed by District Judge Anthony W. Ishii on 1/8/2014. (Non Expert Discovery due by 7/7/2014; Expert Disclosure due by 7/7/2014; Expert Discovery due by 8/25/2014; Non-Dispositive Motions filed by 7/7/2014; Class Certification Motion filed by 8/25/2014; Class Certification Opposition deadline: 9/22/2014; Class Certification Reply due by 10/13/2014) (Figueroa, O)

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DAVID YEREMIAN & ASSOCIATES, INC.
DAVID H. YEREMIAN (SBN 226337)
[e-mail]
HUGO E. GAMEZ (SBN 276765)
[e-mail]
535 N. Brand Boulevard, Suite 705
Glendale, California 91203
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff LETICIA CEJA-CORONA,
on behalf of herself and others similarly situated,

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORIA

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FRESNO DIVISION

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LETICIA CEJA-CORONA, on behalf of
herself and others similarly situated,
Plaintiff,

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Courtroom: 2
Judge: Hon. Anthony Ishii

v.

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Case No. 1:12-CV-01868-AWI-DLB

CVS PHARMACY, INC., a corporation;
and DOES 1 through 50, inclusive,

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Defendants.

JOINT STIPULATION TO CONTINUE
ALL DEADLINES; ORDER
Complaint Filed: October 9, 2012

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COME NOW Plaintiff Leticia Ceja-Corona and Defendant CVS Pharmacy, Inc. (collectively

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hereinafter the “Parties”), through their respective counsel of record, and respectfully submit

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this Joint Stipulation and Proposed Order.

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The Parties hereby stipulate and agree:
1. The Parties have agreed to participate in private mediation before Steve Rottman. The
earliest date on which Mr. Rottman and the Parties are available is April 8, 2014.
2. In order to accommodate the Parties’ desire to prepare for and participate in

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mediation, the Parties respectfully request the Court continue all existing deadlines as

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follows:

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Firmwide:124920096.1 057985.1088

JOINT STIPULATION TO CONTINUE ALL DEADLINES;
PROPOSED ORDER

Case No. 1:12-CV-01868-AWI-DLB

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a. Non Expert Discovery deadline to July 7, 2014;

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b. Expert Disclosure deadline to July 7, 2014;

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c. Non Dispositive Motion Filing Deadline (as to Class Certification issues) to

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July 7, 2013 Hearing pursuant to Local Rules;

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d. Supp. Expert Disclosure deadline to July 28, 2014;

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e. Expert Discovery deadline, including motions to compel related to expert

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discovery, to August 25, 2014;

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f. Class Certification Motion filing deadline to August 25, 2014;

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g. Class Certification Opposition Motion deadline to September 22, 2014; and

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h. Class Certification Reply deadline to October 13, 2014.
SO STIPULATED.

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Dated: January 8, 2014

DAVID YEREMIAN & ASSOCIATES, INC.

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By

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/s/-David Yeremian
David H. Yeremian
Attorneys for Plaintiff LETICIA CEJACORONA, and the Putative Class

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Dated: January 8, 2014

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LITTLER MENDELSON, P.C.
By

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/s/-Jody Landry
Jody Landry
Attorneys for Defendant CVS Pharmacy,
Inc.

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Firmwide:124920096.1 057985.1088

JOINT STIPULATION TO CONTINUE ALL DEADLINES;
PROPOSED ORDER

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Case No. 1:12-CV-01868-AWI-DLB

ORDER

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The Parties having stipulated to the foregoing, and GOOD CAUSE appearing
therefore, IT IS HEREBY ORDERED:
1. The dates indicated below shall be the new deadlines in this matter:

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a. Non Expert Discovery cut-off July 7, 2014;

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b. Expert Disclosure July 7, 2014;

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c. Supp. Expert Disclosure July 28, 2014;

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d. Expert Discovery deadline, including motions to compel related to expert

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discovery, to August 25, 2014;
e. Non Dispositive Motion Filing Deadline (as to Class Certification issues) to
July 7, 2013 Hearing pursuant to Local Rules;

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f. Class Certification Motion Filing deadline August 25, 2014;

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g. Class Certification Opposition Motion deadline September 22, 2014; and

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h. Class Certification Reply deadline October 13, 2014.

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IT IS SO ORDERED.
Dated: January 8, 2014
SENIOR DISTRICT JUDGE

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Firmwide:124920096.1 057985.1088

JOINT STIPULATION TO CONTINUE ALL DATES;
PROPOSED ORDER

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Case No. 1:12-CV-01868-AWI-DLB