Gaddis v. Defender Security Company

Filing 28

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/15/2015 ORDERING that the non-expert discovery deadline is EXTENDED from 5/8/2015 to 9/4/2015, and the expert discovery deadline is EXTENDED from 7/9/2015 to 10/30/2015. (Zignago, K.)

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AMY R. LOVEGREN-TIPTON, State Bar No. 258697)
[e-mail]
LAW OFFICE OF AMY R. LOVEGREN-TIPTON, APLC
5703 N. West Avenue, Suite 103
Fresno, CA 93711
Telephone:
559.421.9137
Facsimile:
559.921.4333
GREGORY C. CHENG, State Bar No. 226865
[e-mail]
BECKI D. GRAHAM, State Bar No. 238010
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870

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Attorneys for Defendant
DEFENDER SECURITY COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JOSE GADDIS, an individual,
Plaintiff,

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Case No. 1:14-cv-01206-TLN-MJS
STIPULATION AND ORDER
EXTENDING DISCOVERY DEADLINES

vs.
DEFENDER SECURITY COMPANY, a
Nevada corporation; and DOES 1 through 25,
inclusive,

Action Filed:

June 24, 2014

Defendant.

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Case No. 1:14-cv-01206-TLN-MJS
STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES

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STIPULATION
IT IS HEREBY STIPULATED AND AGREED by and between plaintiff Jose Gaddis,

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his attorneys of records (“Plaintiff”), and Defendant Defender Security Company, by its attorneys

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of record (“Defendant”), that the following Stipulation may be entered as an Order by the Court to

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give effect to the stipulations set forth below:

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WHEREAS, on June 24, 2014, Plaintiff filed his civil complaint in Fresno County Superior

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Court (“Complaint”). Thereafter, on July 29, 2014, Defendant answered the Complaint. On July

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31, 2014, Defendant removed the case the United States District Court for the Eastern District of

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California.

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WHEREAS, on September 30, 2014, Plaintiff and Defendant filed a joint status report

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wherein the parties indicated they were agreeable to participating in court-sponsored mediation

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through the Court’s Voluntary Dispute Resolution Program (Docket No. 14);

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WHEREAS on November 25, 2014, the Court issued its Pretrial Scheduling Order in which

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it referred the case to the Voluntary Dispute Resolution Program. The Court also ordered the

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parties to complete all non-expert discovery by May 18, 2015 and expert discovery by July 9, 2015

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(Docket No. 17);

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WHEREAS, in anticipation of participating in early court-sponsored mediation, and to

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avoid incurring potentially unnecessary litigation fees, the parties agreed to delay discovery until

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after mediation with the exception of some exchange of written discovery necessary to facilitate the

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mediation process;

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WHEREAS, on March 24, 2015, the Court’s Sacramento Division contacted the parties to
arrange mediation pursuant to the Court’s referral;
WHEREAS, on April 8, 2015, the Court appointed Timothy Long of Orrick Herrington as
neutral for the court-sponsored mediation (Docket No. 26);
WHEREAS, the parties would like to complete mediation on a mutually convenient date to
Mr. Long in June 2015;
WHEREAS the parties would like to defer discovery until after mediation so they can focus
on resolving the case and avoid potentially unnecessary litigation fees;
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Case No. 1:14-cv-01206-TLN-MJS
STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES

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WHEREAS the parties will need additional time to complete discovery should mediation
prove unsuccessful;
THEREFORE, the parties request that the non-expert and expert discovery deadlines be

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extended to September 4, 2015 and October 30, 2015, respectively.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED: April 14, 2015

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LAW OFFICE OF AMY R. LOVEGRENTIPTON, APLC

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By: /s/ Amy R. Lovegren-Tipton
AMY R. LOVEGREN-TIPTON
Attorneys for Plaintiff
JOSE GADDIS

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DATED: April 14, 2015

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By: /s/ Becki D. Graham
GREGORY C. CHENG
BECKI D. GRAHAM
Attorneys for Defendant
DEFENDER SECURITY COMPANY

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Case No. 1:14-cv-01206-TLN-MJS
STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES

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ORDER
GOOD CAUSE APPEARING THEREFORE, IT IS HEREBY ORDERED that the

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non-expert discovery deadline be extended from May 8, 2015 to September 4, 2015, and the expert

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discovery deadline be extended from July 9, 2015 to October 30, 2015.

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IT IS SO ORDERED.

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Dated: April 15, 2015

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Troy L. Nunley
United States District Judge

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Case No. 1:14-cv-01206-TLN-MJS
STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES