Aguilar v. Wawona Frozen Foods et al

Filing 65

STIPULATION and ORDER to Extend Deadlines While the Parties Continue Settlement Negotiations With the Assistance of the Mediator, signed by District Judge Dale A. Drozd on 5/9/2016. (The following deadlines are extended as follows- Phase I Discovery Completion Date: 8/22/2016; Phase I Expert Witness Disclosures: 8/5/2016; Phase I Supplemental Expert Disclosures: 20 days after expert disclosure; Filing of Motion for Class Certification: 9/2/2016.) (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]
Robert W. Sink, Esq. (pro hac vice)
LAW OFFICES OF ROBERT W. SINK
1800 J.F.K. Boulevard, 14th Floor
Philadelphia, PA 19103
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiffs and the proposed Class

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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]

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Attorneys for Defendant WAWONA FROZEN FOODS

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UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF CALIFORNIA
FRESNO DIVISION
LUIS AGUILAR and VIDA RAMOS, on behalf
of themselves and on behalf of all other similarly
situated individuals,
Plaintiffs,

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

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Case No.: 1:15-cv-00093-DAD-EPG
STIPULATION AND ORDER TO
EXTEND DEADLINES WHILE THE
PARTIES CONTINUE SETTLEMENT
NEGOTIATIONS WITH THE
ASSISTANCE OF THE MEDIATOR

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Whereas, the Court’s April 7, 2016 Order set the following deadlines:

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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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Whereas, on May 3, 2016, the Parties attended a mediation before Judge Patrick J. O’Hara

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(retired);
Whereas, the Parties did not reach a settlement but desire to continue settlement
negotiations with the assistance of the mediator;

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Whereas, Defense counsel begins a lengthy trial on May 10, 2016 and after the trial ends;

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Whereas, the Parties have agreed to a forty-five (45) day extension of the above deadlines

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(with a 30-day stay of discovery starting May 6, 2016) to allow the parties to continue to negotiate

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a settlement and potentially avoid the expense of additional discovery.

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THEREFORE, IT IS HEREBY STIPULATED by and between the Parties through their
attorneys of record that the deadlines below be extended as follows:

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Phase I Discovery Completion Date:

August 22, 2016

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Phase I Expert Witness Disclosures:

August 5, 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:

September 2, 2016

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Respectfully submitted,

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LAW OFFICES OF ROBERT W. SINK
Dated: 5/9/16

/s/ Robert Sink
Robert W. Sink
Counsel for the Plaintiffs and the proposed Class

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THE DOWNEY LAW FIRM, LLC

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Dated: 5/9/16

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/s/ Philip Downey
Philip A. Downey
Counsel for the Plaintiffs and the proposed Class

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SAGASER, WATKINS & WIELAND, PC

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Dated: 5/9/16

/s/ Howard Sagaser
Howard A. Sagaser
Counsel for Defendant, Wawona Frozen Foods

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ORDER

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The following deadlines are extended as set forth below:

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Phase I Discovery Completion Date:

August 22, 2016

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Phase I Expert Witness Disclosures:

August 5, 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:

September 2, 2016

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IT IS SO ORDERED.
Dated:

May 9, 2016
UNITED STATES DISTRICT JUDGE

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