Greene v. The Wine Group, Inc. et al

Filing 19

Stipulation to Extend Discovery Cutoff and Expert Designation Dates, and Order, signed by Magistrate Judge Michael J. Seng on 09/18/2015. (Yu, L)

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Kari L. Ley, Cal. Bar No. 142899
The Law Offices of Kari L. Ley
264 Clovis Avenue, Suite 208
Clovis, California 93612
Telephone [phone]
Facsimile [phone]
Attorney for Plaintiff
THOMAS M. GREENE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO DIVISION

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)
)
)
Plaintiff,
)
)
vs.
)
)
)
THE WINE GROUP, INC., a
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California Corporation dba
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Franzia Winery; UNITED FOOD AND )
COMMERCIAL WORKERS UNION LOCAL )
)
8 - GOLDEN STATE a California
)
Corporation; and DOES 1-75
)
inclusive,
)
Defendants. )
)
THOMAS M. GREENE,

Case No. 1:14-CV-01539-KJM/MJS
STIPULATION TO EXTEND DISCOVERY
CUTOFF AND EXPERT DESIGNATION
DATES, AND ORDER

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Whereas the parties were unable to conduct certain

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depositions during July 2015 due to the unavailability of the

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witnesses and counsel; and

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Whereas, counsel for the parties agreed to move the

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depositions back to August to accommodate the calendars of the

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parties and counsel on agreement that the discovery cutoff dates

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and expert designation and discovery dates be moved back to

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accommodate the rescheduling of the depositions;

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Thomas M. Greene v. The Wine Group, Inc., et al. - 1

The parties through their counsel herby agree and stipulate

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as follows:
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be moved from September 1, 2015, to September 22, 2015;
2.

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The deadline for completing non expert discovery shall

The deadline for designating experts shall be moved

back from September 15, 2015, to October 6, 2015;
3.

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The deadline for supplementing expert designations

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shall be moved back from October 1, 2015, to October 22, 2015;

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and

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4.

The deadline to complete expert witness discovery

shall be moved back from October 14, 2015, to November 4, 2015.

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Dated:

August 26, 2015

The Law Office of Kari L. Ley
/s/ Kari L. Ley
_________________________
Kari L. Ley, Attorney for
Plaintiff THOMAS M. GREENE

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Dated:

August 27, 2015

Jackson Lewis PC
/s/ Keahn N. Morris
__________________________
Keahn N. Morris, Attorneys
for Defendant The Wine Group,
Inc.

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Dated:

August 27, 2015

Davis, Cowell & Bowe, LLP
/s/ David L. Barber
__________________________
David L. Barber, Attorneys
for Defendant United Food And
Commercial Workers Union
Local 8-Golden State

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Thomas M. Greene v. The Wine Group, Inc., et al. - 2

ORDER

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Good cause appearing, the parties’ stipulation in Case No.

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1:14-CV-01539-KJM/MJS TO EXTEND DISCOVERY CUTOFF AND EXPERT

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DESIGNATION DATES is accepted and adopted and made the Order of

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the Court. Dispositive motion, pretrial and trial dates shall

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remain as previously set.

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IT IS SO ORDERED.
Dated:

September 17, 2015

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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Thomas M. Greene v. The Wine Group, Inc., et al. - 3