Quinones v. Donahoe

Filing 27

STIPULATION and ORDER to Continue Pre-Trial Dates and set a Settlement Conference for 6/25/2015 at 10:30 AM in Courtroom 10 (GSA) before Magistrate Judge Gary S. Austin, signed by Magistrate Judge Gary S. Austin on 5/21/2015. (Kusamura, W)

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BENJAMIN B. WAGNER
United States Attorney
ALYSON A. BERG
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, California 93721
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant PATRICK R. DONAHOE,
POSTMASTER GENERAL, UNITED STATES
POSTAL SERVICE

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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FELIPE S. QUINONES,

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Plaintiff,

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v.

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PATRICK R. DONAHOE, POSTAMASTER
GENERAL, UNITED STATES POSTAL
SERVICE,

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Defendant.

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) Case No. 1:13-cv-01553 LJO/GSA
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) STIPULATION TO CONTINUE
) PRE-TRIAL DATES; ORDER
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Plaintiff Felipe S. Quinones (“Plaintiff”), and Defendant Patrick R. Donahoe, Postmaster

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General (“Defendant”), (collectively “the parties”), stipulate, by and through the undersigned

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counsel, to extend the discovery deadlines in this action to allow for the parties to engage in

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settlement negotiations. The dates for filing motions, the pre-trial conference, and the trial date are

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not affected by this stipulation.

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The parties agree to a short extension of the dates to allow the parties to meaningfully

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participate in a settlement conference set for June 25, 2015 at 10:30 a.m. before the Honorable Gary

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S. Austin. The parties submit that this request is being made for good cause to allow the parties to

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attempt to resolve the case at this time, and prior to extensive discovery, depositions and pre-trial

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disclosures. The stipulation provides a change of approximately two months to the discovery cut-off

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deadline, without changing the pre-trial conference or trial dates.

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Accordingly, the parties stipulate and agree to continue the following dates, and base it on the
above-stated good cause.
Old Date

New Date

Settlement Conference

TBA

June 25, 2015
@ 10:30 a.m. Ctrm 10

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Close of Non-Expert
Discovery

July 31, 2015

September 30, 2015

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Plaintiff’s Expert Disclosure

August 24, 2015

October 8, 2015

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Defendant’s Expert Disclosure

September 14, 2015

October 28, 2015

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Rebuttal Expert Disclosure

September 28, 2015

November 2, 2015

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Expert Discovery Cut-Off

November 23, 2015

December 1, 2015

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The parties request the court to endorse this stipulation by way of formal order.

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Dated: May 21, 2015

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Respectfully submitted,
BENJAMIN B. WAGNER
UNITED STATES ATTORNEY

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/s/Alyson A. Berg
ALYSON A. BERG
Attorney for Defendant Patrick R. Donahoe,
Postmaster General, United States Postal Service

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Dated: May 21, 2015

Church State Council

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/s/Alan J. Reinach
Alan J. Reinach
Attorneys for Plaintiff

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ORDER

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Having reviewed the stipulation submitted by the parties, the dates are continued as

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referenced above.

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IT IS SO ORDERED.

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Dated:

May 21, 2015

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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