Quinones v. Donahoe

Filing 39

STIPULATION to Continue Non-Expert Discovery Deadline; ORDER re 38 signed by Magistrate Judge Gary S. Austin on 9/8/2015. (Martinez, A)

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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 MEGAN J. BRENNAN,
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,
Plaintiff,

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v.
MEGAN J. BRENNAN, POSTMASTER
GENERAL, UNITED STATES POSTAL
SERVICE,
Defendant.

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Case No. 1:13-cv-01553-LJO-GSA
STIPULATION TO CONTINUE
NON-EXPERT DISCOVERY DEADLINE;
ORDER
(ECF No. 38)

Plaintiff Felipe S. Quinones (“Plaintiff”), and Defendant Megan J. Brennan, Postmaster

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

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counsel, to extend the non-expert discovery deadline. The dates for filing motions, the pre-trial

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conference, and the trial date are not affected by this stipulation.

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The parties agree to a short extension of the date by which to complete non-expert discovery

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in this case from September 30, 2015 to December 1, 2015, the same day on which expert discovery

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is to be completed. The parties submit that this request is being made for good cause as the parties

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attempted to resolve the matter at a settlement conference on August 26, 2015, which attempt was

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unsuccessful. The parties are seeking to phase discovery to conserve time and resources during this

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brief extension of the non-expert discovery deadline. Accordingly, the parties stipulate and agree to

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continue the non-expert discovery deadline, and base it on the above-stated good cause.

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STIPULATION TO CONTINUE NON-EXPERT DISCOVERY DEADLINE; ORDER

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Old Date

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Close of Non-Expert
Discovery

New Date

September 30, 2015

December 1, 2015

The parties request the court to endorse this stipulation by way of formal order.
Dated: September 3, 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 Megan J. Brennan,
Postmaster General, United States Postal Service

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Dated: September 3, 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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After a review of the above stipulation and the procedural posture of the case, and good

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cause appearing therein, the non-expert discovery deadline is continued to December 1, 2015. The

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Court notes that the non-dispositive motion deadline is currently set for December 14, 2015.

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Compliance with this deadline and the newly set non-expert discovery deadline will require

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discovery motions to be filed and heard sufficiently in advance of the specified deadlines so that the

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Court may grant effective relief within the allotted discovery time. A party's failure to have a

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discovery dispute heard sufficiently in advance of the discovery cutoff may result in denial of the

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motion as untimely.

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IT IS SO ORDERED.

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Dated:

September 8, 2015

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO CONTINUE NON-EXPERT DISCOVERY DEADLINE; ORDER

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