Greene v. The Wine Group, Inc. et al

Filing 21

Stipulation To Extend Expert Designation and Expert Discovery Dates, and Order, signed by Magistrate Judge Michael J. Seng on 10/05/2015. (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
)
California Corporation dba
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Franzia Winery; UNITED FOOD AND )
COMMERCIAL WORKERS UNION LOCAL )
)
8 - GOLDEN STATE a California
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Corporation; and DOES 1-75
)
inclusive,
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Defendants. )
)
THOMAS M. GREENE,

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

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Whereas, the parties have completed non expert discovery;

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and
Whereas, Plaintiff and Defendant UNITED FOOD AND COMMERCIAL

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WORKERS UNION LOCAL 8 - GOLDEN STATE ("UNION") have agreed to

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resolution of their disputes and are in the process of preparing

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the necessary documentation; and

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Whereas, Plaintiff and the remaining Defendant THE WINE

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GROUP, INC., are currently involved in settlement discussions

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including possible mediation; and

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

Whereas, the parties wish to move back the dates for the

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exchanging expert witness information and completion of expert

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witness discovery to allow them to finalize the documentation

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resolving the disputes between Plaintiff and the UNION, and to

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complete settlement discussions between Plaintiff and THE WINE

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GROUP, INC.;
The parties through their counsel herby agree and stipulate

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as follows:
1.

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The deadline for the initial designation of experts

shall be moved back from October 6, 2015, to November 3, 2015;
2.

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The deadline for supplementing expert designations

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shall be moved back from October 22, 2015, to November 19, 2015;

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and
3.

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The deadline to complete expert witness discovery

shall be moved back from November 4, 2015, to December 2, 2015.

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Dated:

October 2, 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:

October 2, 2015

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

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/

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/

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

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Dated:

October 2, 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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ORDER
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Good cause appearing, the STIPULATION TO EXTEND EXPERT

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DESIGNATION AND EXPERT DISCOVERY DATES in Case No. 1:14-CV-01539-

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KJM/MJS is approved and made the Order of the Court. All other dates remain as

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previously ordered.

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IT IS SO ORDERED.

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Dated:
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October 5, 2015

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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