Zapata v. The Neil Jones Food Co.

Filing 35

STIPULATION and ORDER GRANTING the parties' request for an extension of the following deadlines: Expert Witness Disclosure due by 7/29/2016; Rebuttal Expert Witness Disclosure due by 8/29/2016; and Expert Discovery to be completed by 9/30/2016. Order signed by Magistrate Judge Erica P. Grosjean on 5/16/2016. (Rooney, M)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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GRACIE ZAPATA, an individual,

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3000 Lake ore Avenue
FirmName1_1as,l hfFirmLegalStatus1_1
Oakland, C i ornia 94610

FOSTERemploymentlaw

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Plaintiff,
vs.
THE NEIL JONES FOOD CO., a
Corporation; and Does 1 through 10,
inclusive,
Defendants.

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Case No. 1:14-CV-02027-EPG
Trial Date: October 18, 2016
Date Action Filed: October 28, 2014
STIPULATION AND JOINT REQUEST
FOR ORDER EXTENDING DEADLINES
TO DISCLOSE EXPERT WITNESSES
AND TO COMPLETE DISCOVERY
FROM EXPERTS; ORDER EXTENDING
DEADLINES

WHEREAS in paragraph 6 of their Joint Scheduling Report filed February 17, 2015 (ECF

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No. 4), the parties requested that the deadlines to disclose expert witnesses and take discovery from

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experts be set sufficiently after the hearing on dispositive motions so that the parties are not required

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to incur the expense of retaining experts and having reports prepared on issues that are disposed of

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prior to trial by way of those motions;

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WHEREAS the parties renewed the above request in their Addendum to Joint Scheduling
Report filed March 3, 2015 (ECF No. 8);
WHEREAS the Scheduling Conference Order filed March 4, 2015 (ECF No. 10) set the

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initial deadline for disclosure of expert witnesses for May 16, 2016, which was almost sixty (60)

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days after dispositive motions were to be heard;

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WHEREAS both parties filed dispositive motions on February 26, 2016, which was the
deadline set by the Scheduling Conference Order for the filing of such motions;

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WHEREAS the parties’ dispositive motions were initially scheduled for hearing on March

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24, 2016, but the hearing on those motions was continued to May 6, 2016 to accommodate

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the Court’s and the parties’ counsel’s schedules;
NOW THEREFORE, the parties through counsel stipulate and jointly request that the Court

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GRACIE ZAPATA V. THE NEIL JONES FOOD COMPANY
CASE NO. 1:14-CV-02027-EPG
STIPULATION AND ORDER EXTENDING DEADLINES FOR EXPERT DISCLOSURES AND DISCOVERY

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extend the deadlines to make expert witness disclosures, to make rebuttal expert witness disclosures,

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and to complete discovery from expert witnesses as follows:

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Expert witness disclosure deadline

July 29, 2016

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Rebuttal expert witness disclosure deadline

August 29, 2016

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Deadline to complete discovery from experts

September 30, 2016

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IT IS SO STIPULATED AND JOINTLY REQUESTED.

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Date: May 10, 2016

FOSTER EMPLOYMENT LAW

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By: /s/ MICHAEL E. WILBUR
MICHAEL E. WILBUR
Attorneys for Defendant
THE NEIL JONES FOOD COMPANY

3000 Lake ore Avenue
FirmName1_1as,l hfFirmLegalStatus1_1
Oakland, C i ornia 94610

FOSTERemploymentlaw

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Date: May 10, 2016

LAW OFFICE OF KEVIN SCHWIN

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By: /s/ KEVIN SCHWIN
KEVIN SCHWIN
Attorney for Plaintiff
GRACIE ZAPATA

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ORDER

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The Court has reviewed the above joint request and adopts the stipulation. (Doc. 29). The

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following deadlines shall be modified in this Court’s scheduling order issued on March 4,

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2015. (Doc. 10).

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Expert witness disclosure deadline

July 29, 2016

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Rebuttal expert witness disclosure deadline

August 29, 2016

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Deadline to complete discovery from experts

September 30, 2016

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IT IS SO ORDERED.

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Dated:

May 16, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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GRACIE ZAPATA V. THE NEIL JONES FOOD COMPANY
CASE NO. 1:14-CV-02027-EPG
STIPULATION AND ORDER EXTENDING DEADLINES FOR EXPERT DISCLOSURES AND DISCOVERY