Lawrence v. Schlumberger Technology Corporation

Filing 20

STIPULATION and ORDER to Continue Discovery and Trial Date re 19 , signed by Magistrate Judge Jennifer L. Thurston on 5/12/2015. Non-Expert Discovery Deadline 7/17/2015. Expert Discovery Deadline 10/12/2015. Non-Dispositive Motion Deadlines: Filed by 10/19/2015; Hearing by 11/20/2015. Dispositive Motion Deadlines: Filed by 7/28/2015; Hearing by 9/1/2015. Pretrial Conference set for 11/23/2015 at 10:00 AM in Bakersfield at 510 19th Street (JLT) before Magistrate Judge Jennifer L. Thurston. Bench Trial continued to 1/11/2016 at 08:30 AM in Bakersfield at 510 19th Street (JLT) before Magistrate Judge Jennifer L. Thurston. (Hall, S)

1 KENNETH F. MOSS (SBN 94185)
LAW OFFICES OF KENNETH F. MOSS
2 [e-mail]
20335 Ventura Blvd., Suite 430
3 Woodland Hills, California 91364
Tel: [phone]
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Attorneys for Plaintiff
5 KENNETH LAWRENCE
6 MORGAN LEWIS & BOCKIUS LLP
JASON MILLS (SBN 225126)
7 PATRICIA S. RIORDAN (SBN 187418)
[e-mail]
8 [e-mail]
300 South Grand Avenue
9 Twenty-Second Floor
Los Angeles, CA 90071-3132
10 Tel: [phone]
Fax: [phone]
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Attorneys for Defendant
12 SCHLUMBERGER TECHNOLOGY CORP.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KENNETH LAWRENCE,
Plaintiff,
v.

SCHLUMBERGER TECHNOLOGY
20 CORPORATION, a Texas corporation;
and DOES 1-20 inclusive,
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Defendants.
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Case No. 1:14-cv-00524 JLT
JOINT STIPULATION AND
[PROPOSED] ORDER TO
CONTINUE DISCOVERY AND
TRIAL DATE
(Doc. 19)

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Pursuant to Local Rules 143 and 144, Plaintiff Kenneth Lawrence

26 (“Plaintiff”) and Defendant Schlumberger Technology Corporation (“Defendant”),
27 by and through their attorneys of record, submit this joint stipulation:
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-1STIPULATION RE: CONT. DISC. AND TRIAL DATE

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WHEREAS, on March 31, 2015, the Court granted the request of counsel to

2 extend the discovery pertaining to non-experts to June 10, 2015 , and expert
3 discovery to August 26, 2015;
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WHEREAS, Plaintiff noticed a 30(b)(6) deposition out of state for which

5 Defendant requires additional time to identify the Person Most Knowledgeable as to
6 the specific topics, which are focused on a particular time frame, and thereafter for
7 the parties to identify mutually agreeable dates for the deposition;
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WHEREAS, the Parties are in the process of meeting and conferring about

9 supplemental responses to interrogatories served on Defendant on February 24,
10 2015, and Defendant intends to provide supplemental responses to interrogatories on
11 or before May 18, 2015 so the Parties can resolve any disputes informally;
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WHEREAS, to avoid unnecessarily expending the parties’ and judicial

13 resources, the Parties to seek to push back the deadline by which Defendant must
14 file a motion for summary judgment and for which the motion must be heard;
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WHEREAS, the extension will permit the Parties time to conduct this

16 additional discovery and thereafter evaluate the prospects for settlement and
17 potentially schedule a settlement conference with a Magistrate Judge;
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THEREFORE, IT IS STIPULATED by the parties and respectfully requested

19 that the Court make the following changes to the Court’s calendar:
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1.

Non-expert discovery cut-off shall be continued from June 10, 2015 to

21 July 17, 2015;
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2.

The Parties shall disclose all expert witnesses, in writing, on or before

23 August 17, 2015 and to disclose all rebuttal experts on or before September 14,
24 2015;
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3.

Expert discovery cut-off shall be continued from August 26, 2015 to

26 October 12, 2015;
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-2STIPULATION RE: CONT. DISC. AND TRIAL DATE

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2.

The deadline for Parties to bring dispositive motions shall be continued

2 from May 19, 2015 to July 28, 2015;
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3.

The deadline for dispositive motions to be heard shall be continued

4 from June 30, 2015 to September 8, 2015;
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4.

The trial shall be continued from September 21, 2015 to November 16,

6 2015;
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IT IS SO STIPULATED,

8 Dated:

May 11, 2015

MORGAN, LEWIS & BOCKIUS LLP

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By

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14 Dated:

May 11, 2015

/s/ Patricia Riordan
Jason Mills
Patricia Riordan
Attorneys for Defendant
SCHLUMBERGER
TECHNOLOGY CORPORATION

LAW OFFICE OF KENNETH F. MOSS

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By

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/s/ Kenneth Moss
Kenneth F. Moss
Attorneys for Plaintiff
KENNETH LAWRENCE

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ORDER

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Based upon the foregoing, the Court ORDERS the case schedule amended as follows:

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1.

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expert discovery SHALL be completed no later than October 12, 2015;

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2.

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17, 2015 and disclose all rebuttal experts no later than September 14, 2015;

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3.

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no later than November 20, 2015;

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All non-expert discovery SHALL be completed no later than July 17, 2015 and all

The Parties SHALL disclose all expert witnesses, in writing, no later than August

Nondispositive motions SHALL be filed no later than October 19, 2015 and heard

-3STIPULATION RE: CONT. DISC. AND TRIAL DATE

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than September 1, 2015;

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The pretrial conference is CONTINUED to November 23, 2015 at 10:00 a.m.;

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The trial is CONTINUED to January 11, 2016 at 8:30 a.m.

Dispositive motions SHALL be filed no later than July 28, 2015 and heard no later

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IT IS SO ORDERED.
Dated:

May 12, 2015

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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-4STIPULATION RE: CONT. DISC. AND TRIAL DATE