Silveira et al v. State of California et al

Filing 40

STIPULATION and JOINT Request to Continue Mandatory Scheduling Conference; ORDER - Initial SCHEDULING CONFERENCE is continued from 9/16/2013 to November 18, 2013 at 09:00 AM in Courtroom 8 (BAM) before Magistrate Judge Barbara A. McAuliffe. signed by Magistrate Judge Barbara A. McAuliffe on 8/13/2013. (Herman, H)

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BLECHER COLLINS PEPPERMAN & JOYE, P.C.
Maxwell M. Blecher (State Bar No. 26202)
[e-mail]
Donald R. Pepperman (State Bar No. 109809)
[e-mail]
Majed Dakak (State Bar No. 271875)
[e-mail]
515 South Figueroa Street, Suite 1750
Los Angeles, CA 90071
Phone: [phone]
Fax:
[phone]

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Attorneys for PLAINTIFFS and CONSENTERS

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(Appearances for Additional Counsel on Next Page)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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CARLOS SILVEIRA, GEORGETTE
PICKETT, and CHARLES HUGHES, as
individuals, and on behalf of all others similarly
situated,

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Case No. 1:13-CV-00084-AWI-BAM
STIPULATION AND JOINT REQUEST
TO CONTINUE MANDATORY
SCHEDULING CONFERENCE; ORDER

Plaintiffs,
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vs.
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JEFFREY A. BEARD, in his capacity as the
Secretary of the California Department of
Corrections and Rehabilitation; and DOES 2
through 10, inclusive,
Defendants.

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STIPULATION AND JOINT REQUEST TO CONTINUE SCHEDULING CONFERENCE

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DIVERSITY LAW GROUP, P.C.
Larry W. Lee (State Bar No. 228175)
[e-mail]
550 South Hope Street, Suite 2655
Los Angeles, CA 90071
Phone: [phone]
Fax:
[phone]
HYUN LEGAL, APC
Dennis S. Hyun (State Bar No. 224240)
[e-mail]
550 South Hope Street, Suite 2655
Los Angeles, CA 90071
Phone: [phone]
Fax:
[phone]

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STIPULATION AND JOINT REQUEST TO CONTINUE SCHEDULING CONFERENCE

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Whereas, the Court has set the Mandatory Scheduling Conference for September 16, 2013;

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Whereas, counsel for Plaintiffs and Defendant (collectively, the “Parties”) have been engaged in

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informal meet and confer discussions regarding potentially resolving this case, including without

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limitation, informally exchanging discovery;

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Whereas, at this stage of the litigation, the Parties are optimistic that continuing with informal
exchange of discovery will more efficiently resolve open issues related to this matter;

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Whereas, Rule 26 of the Federal Rules of Civil Procedure require the Parties to confer over a

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proposed discovery plan by August 27, 2013, submit a discovery plan 14 days afterwards, and make

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initial disclosures by September 9, 2013;

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Whereas, the Parties agree that continuing the Mandatory Scheduling Conference and related

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deadlines will facilitate a potential resolution of this action and conserve the resources of the Court and

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the Parties;

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Accordingly, the Parties to this action, through their respective attorneys of record, hereby

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STIPULATE and JOINTLY REQUEST this Court continue the Mandatory Scheduling Conference, and

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related deadlines to meet and confer and submit a Joint Scheduling Report and discovery plan, and

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deadline to provide initial disclosures, for sixty (63) days, or November 18, 2013, or to a date and time

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thereafter that is convenient for the Court.

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Dated:

August 13, 2013

Respectfully submitted,

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JOAN A. MARKOFF
Chief Counsel

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DAVID J. NEILL
Deputy Chief Counsel

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By: _/s/ David D. King_______________
DAVID D. KING,
Labor Relations Counsel
Attorney for Defendant

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STIPULATION AND JOINT REQUEST TO CONTINUE SCHEDULING CONFERENCE

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Dated:

August 13, 2013

Respectfully submitted,
By: /s/ Majed Dakak
MAJED DAKAK
Attorney for Plaintiffs

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STIPULATION AND JOINT REQUEST TO CONTINUE SCHEDULING CONFERENCE

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ORDER

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In consideration of the Parties’ Stipulation and Joint Request to Continue the Mandatory

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Scheduling Conference, and related deadlines, and good cause having been shown, it is ORDERED that

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the Mandatory Scheduling Conference, currently set for September 16, 2013, shall be continued to

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November 18, 2013, at 9:00 AM in Courtroom 8 before United States Magistrate Judge Barbara A.

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McAuliffe. Related deadlines to meet and confer and submit a Joint Scheduling Report, to provide

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initial disclosures, and to meet and confer and provide a written discovery plan under Rule 26 of the

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Federal Rules of Civil Procedure, are similarly continued.

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IT IS SO ORDERED.
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Dated:

/s/ Barbara

August 13, 2013

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND JOINT REQUEST TO CONTINUE SCHEDULING CONFERENCE