Aguilar v. Wawona Frozen Foods et al

Filing 60

STIPULATION to Extend Deadlines While the Parties Attend Mediation; ORDER, signed by District Judge Dale A. Drozd on 4/7/2016. (Case schedule modified as follows- 55 Motion for Order Requiring Plaintiff to Submit a Trial Plan previously set for 4/1 9/2016, is CONTINUED to 6/13/2016, at 2:30pm in Courtroom 5 before District Judge Dale A. Drozd; Phase I Discovery Completion Date: 7/8/2016; Phase I Expert Witness Disclosures: 6/21/2016; Phase I Supplemental Expert Disclosures: 20 days after expert disclosure; Filing of Motion for Class Certification: 7/19/2016.)(Gaumnitz, R)

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Philip A. Downey (pro hac vice)
Cory G. Lee, Esq. (SBN 216921)
THE DOWNEY LAW FIRM, LLC
9595 Wilshire Blvd., Suite 900
Beverly Hills, California 90212
Tel: [phone]
Fax: [phone]

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Attorney for Plaintiffs and the proposed Class
Howard A. Sagaser (SBN 72492)
Ian B. Wieland (SBN 285721)
SAGASER, WATKINS & WIELAND, PC
7550 North Palm Avenue, Suite 100
Fresno, California 93711
Tel: [phone]
Fax: [phone]
Attorneys for Defendant WAWONA FROZEN FOODS

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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LUIS AGUILAR and VIDA RAMOS, on
behalf of themselves and on behalf of all
other similarly situated individuals,

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Plaintiffs,
v.

No. 1:15-cv-00093-DAD-EPG

STIPULATION TO EXTEND DEADLINES
WHILE THE PARTIES ATTEND
MEDIATION; ORDER

WAWONA FROZEN FOODS;
WAWONA EXPORT; WAWONA
PACKING CO. LLC, and DOES 1–50,
inclusive,
Defendants.

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Whereas, the Court’s May 20, 2015 Pretrial Scheduling Order bifurcating discovery and
the Court’s January 26, 2016 Order set the following deadlines:

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Phase I Discovery Completion Date:

May 9, 2016

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Phase I Expert Witness Disclosures:

April 22, 2016
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Phase I Supplemental Expert Disclosures:

20 days after expert disclosure

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Filing of Motion for Class Certification:

May 20, 2016

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Whereas, the Parties have agreed to mediate this case before Judge Patrick J. O’Hara

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(retired) on May 3, 2016;
Whereas, the Parties have agreed to a sixty (60) day extension of the above deadlines to
allow the parties to focus on mediation and potentially avoid the expense of additional discovery.
THEREFORE, IT IS HEREBY STIPULATED by and between the Parties through their
attorneys of record that the deadlines below be extended by sixty (60) days as follows:
Motion for Order Requiring Plaintiff to Submit a Trial Plan is set for June 13, 2016.

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Phase I Discovery Completion Date:

July 8, 2016

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Phase I Expert Witness Disclosures:

June 21, 2016

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Phase I Supplemental Expert Disclosures:

20 days after expert disclosure

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Filing of Motion for Class Certification:

July 19, 2016

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Respectfully submitted,

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THE DOWNEY LAW FIRM, LLC

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Dated: 04/06/16

/s/ Philip Downey

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Philip A. Downey

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Counsel for the Plaintiffs and the proposed Class

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SAGASER, WATKINS & WIELAND, PC
Dated: 04/06/16

/s/ Ian Weiland

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Ian Weiland

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Counsel for Defendant, Wawona Frozen Foods

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ORDER
The following deadlines are extended as set forth below:

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Motion for Order Requiring Plaintiff to Submit a Trial Plan is set for June 13, 2016.

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Phase I Discovery Completion Date:

July 8, 2016

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Phase I Expert Witness Disclosures:

June 21, 2016

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Phase I Supplemental Expert Disclosures:

20 days after expert disclosure

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Filing of Motion for Class Certification:

July 19, 2016

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IT IS SO ORDERED.
Dated:

April 7, 2016
UNITED STATES DISTRICT JUDGE

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