Sanchez v. Target Corporation

Filing 22

STIPULATION and ORDER to CONTINUE DEADLINES: Non-Expert Discovery due by 9/24/2015; Expert Disclosures due by 10/8/2015; Supplemental Expert Disclosures due by 10/22/2015; Expert Discovery due by 11/17/2015. Non-Dispositive and Dispositive Motions shall be filed by 11/18/2015, and heard by 12/16/2015. Settlement Conference set for 10/27/2015, at 10:30 AM in Courtroom 9 (SAB) before Magistrate Judge Stanley A. Boone. Pretrial Conference set for 1/27/2016, at 02:00 PM in Courtroom 7 (SKO) before Magistrate Judge Sheila K. Oberto. Jury Trial set for 3/8/2016, at 08:30 AM in Courtroom 7 (SKO) before Magistrate Judge Sheila K. Oberto. Order signed by Magistrate Judge Sheila K. Oberto on 3/19/2015. (Timken, A)

1
2
3
4
5
6
7
8
9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11

FRESNO

12
13

SANDRA SANCHEZ,

14
15
16
17

Case No. 1:14-cv-00761-SKO

Plaintiff,

STIPULATION AND ORDER TO
CONTINUE DEADLINES

v.
TARGET CORPORATION,
Defendant.

18
19
20
21
22
23
24
25
26

Pursuant to Civ. L.R. 144, and subject to approval of the Court, Plaintiff Sandra Sanchez
(“Plaintiff”) and Defendant Target Corporation (“Target”), by and through their attorneys enter
into the following stipulation and respectfully request the Court’s acceptance of this stipulation:
WHEREAS, on August 27, 2014 the Court issued a Scheduling Order (“Scheduling
Order”) in the above referenced action;
WHEREAS, pursuant to the Scheduling Order, the deadline for Non Expert Discovery is
April 17, 2015, the deadline for Expert Disclosure is May 1, 2015, the deadline for Supplemental
Expert Disclosure is May 15, 2015, and the deadline for Expert Discovery is June 10, 2015;

27
28

1
STIPULATION AND ORDER TO CONTINUE DEADLINES
CASE NO. 1:14-CV-00761-SKO

1
2

WHEREAS, pursuant to the Scheduling Order, the deadline to file dispositive motions is
June 12, 2015, and the deadline for hearing on dispositive motions is July 15, 2015;

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26

WHEREAS, pursuant to the Scheduling Order, the Settlement Conference is set for April
27, 2015, the Pretrial Conference is set for August 19, 2015, and Trial is set for September 29,
2015;
WHEREAS, the parties have informally engaged in settlement discussions for the last
three months, during which time the parties conducted informal discovery to conserve resources
while attempting to settle this matter;
WHEREAS, it has taken the parties more time than expected to mutually agree on a
mediator and to schedule a mediation date;
WHEREAS, the parties have a mediation set for April 15, 2015 with Buzz Wiesenfeld of
Judicate West;
WHEREAS, the parties agree that they would like to avoid the expense of time and
resources associated with further discovery in this matter while they engage in settlement
discussions and attend mediation. The parties believe that a continuance of the current trial date
and all related scheduled dates will promote judicial economy in that the parties will be able to
delay incurring further litigation expenses until after the mediation;
WHEREAS, the parties have met and conferred regarding continuing the dates set forth
in the Court’s August 27th scheduling order;
WHEREAS, Defendant is unavailable in December 2015 and counsel for Plaintiff is
unavailable in January and February 2016 due to trials in other cases;
WHEREAS, the parties respectfully request that the Court vacate the current trial date
and pretrial deadlines and reschedule all associated dates and deadlines by approximately 160
days at times convenient for the Court and counsel. This additional time will allow the parties to
continue engaging in settlement discussions, and complete discovery before the dispositive
motion deadline, assuming mediation is unsuccessful;

27
28

2
STIPULATION AND ORDER TO CONTINUE DEADLINES
CASE NO. 1:14-CV-00761-SKO

1

WHEREAS, the Parties have not requested any prior extension in this matter.

2
3

NOW, THEREFORE, the Parties agree and stipulate, subject to the approval of the
Court, that:

4
5

1.

September 24, 2015;

6
7

2.

3.

4.

14

5.

17
18
19

The June 12, 2015 deadline to file dispositive motions be continued to on or after

November 19, 2015 and the deadline for hearing on dispositive motions to be continued to
February 22, 2016;

15
16

The June 10, 2015 deadline for Expert Discovery be continued to on or after

November 17, 2015;

12
13

The May 15, 2015 deadline for Supplemental Expert Disclosure be continued to

on or after October 22, 2015;

10
11

The May 1, 2015 deadline for Expert Disclosure be continued to on or after

October 8, 2015;

8
9

The April 17, 2015 deadline for Non-Expert Discovery be continued to on or after

6.

The April 27, 2015 Settlement Conference be continued to on or after October 5,

2015, and the August 19, 2015 Pretrial Conference be continued to on or after January 26, 2016;
and
7.

The September 29, 2015 Trial date be continued to on or after March 7, 2016;

IT IS SO STIPULATED

20
21

DATED: March 17, 2015

SEYFARTH SHAW LLP

22

By:

/s/ Courtney K. Bohl
Courtney K. Bohl
Attorneys for Defendant
TARGET CORPORATION

23
24
25
26
27
28

3
STIPULATION AND ORDER TO CONTINUE DEADLINES
CASE NO. 1:14-CV-00761-SKO

1

DATED: March 16, 2015

LAW OFFICE OF DEAN B. GORDON

2

By:

/s/ Dean B. Gordon
Dean B. Gordon
Attorney for Plaintiff SANDRA SANCHEZ

3
4

ORDER
5

Pursuant to the parties' stipulation, the case deadlines are modified as follows:

6
7

Event

Current Date

Modified Date1

8

Non-Expert Discovery

April 17, 2015

September 24, 2015

9

Expert Disclosure

May 1, 2015

October 8, 2015

10

Suppl. Expert Disclosure

May 15, 2015

October 22, 2015

11

Expert Discovery

June 10, 2015

November 17, 2015

12

Motion Filing Deadline

June 12, 2015

November 18, 2015

13

Motion Hearing Deadline

July 25, 2015

December 16, 2015

14

Settlement Conference

April 27, 2015

October 27, 2015 at 10:30
a.m. in Courtroom 9

Pre-trial Conference

August 19, 2015

January 27, 2016

Trial

September 29, 2015

March 8, 2016

15
16
17
18
19

IT IS SO ORDERED.

20
Dated:

March 19, 2015

/s/ Sheila K. Oberto

21

UNITED STATES MAGISTRATE JUDGE

22
23
24
25
26

1

27

In light of the parties' requested trial date of March 7, 2016, the parties' requested February 22, 2016, deadline for
hearing all motions could not be accommodated. The dates for motion hearings, settlement conference, pre-trial
conference, and trial have been adjusted by a few days to comport with the Court's calendar.

28

4
STIPULATION AND ORDER TO CONTINUE DEADLINES
CASE NO. 1:14-CV-00761-SKO