Greene v. The Wine Group, Inc. et al

Filing 25

Stipulation To Extend Expert Designation And Expert Discovery Dates, and Order, signed by Magistrate Judge Michael J. Seng on 10/30/2015. (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 )
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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 filing a

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Request for Dismissal of the UNION as well as the first and

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second causes of action in the Complaint against THE WINE GROUP,

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INC.; and

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

Whereas, Plaintiff and the remaining Defendant THE WINE

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GROUP, INC., are currently involved in settlement discussions

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and have scheduled a mediation to take place on November 12,

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2015; and
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 submit the Request for

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Dismissal of the UNION to the Court, and to complete settlement

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discussions between Plaintiff and THE WINE GROUP, INC.,

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including the mediation scheduled for November 12, 2015;
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 November 3, 2015, to December 2, 2015;
2.

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The deadline for supplementing expert designations

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shall be moved back from November 19, 2015, to December 17,

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2015; and
3.

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The deadline to complete expert witness discovery

shall be moved back from December 2, 2015, to January 8, 2015.

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Dated:

October 29, 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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Thomas M. Greene v. The Wine Group, Inc., et al. - 2

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Dated:

October 29, 2015

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

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Dated:

October 30, 2015

Davis, Cowell & Bowe, LLP

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/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 proposed Order to Extend Expert

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Designation and Expert Discovery in Case No. 1:14-CV-1539-KJM-

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MJS, is hereby approved and adopted as the Order of the Court.

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IT IS SO ORDERED.

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Dated:

October 30, 2015

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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