Talavera v. Leprino Foods Company et al

Filing 20

STIPULATION for Extension to Discovery Cutt-Off; ORDER - that the pending non-expert discovery cut-off deadline is continued from 12/15/2015 to January 9, 2016. signed by Magistrate Judge Barbara A. McAuliffe on 9/23/2015. (Herman, H)

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Philip A. Downey (admitted pro hac vice)
Pennsylvania Attorney ID No. 81603
The Downey Law Firm, LLC
P.O. Box 1021
Unionville, Pa 19375
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Cory G. Lee, Esq. (SBN 216921)
THE DOWNEY LAW FIRM, LLC (Of Counsel)
9595 Wilshire Blvd., Suite 900
Beverly Hills, California 90212
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff and the proposed Class
HANSON BRIDGETT LLP
SANDRA L. RAPPAPORT, SBN 172990
[e-mail]
EMILY H. FULMER, SBN 279419
[e-mail]
425 Market Street, 26th Floor
San Francisco, California 94105
Tel: [phone]
Fax: [phone]
Attorneys for Defendants
LEPRINO FOODS COMPANY and LEPRINO
FOODS DAIRY PRODUCTS COMPANY

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UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF CALIFORNIA
FRESNO DIVISION
JONATHON TALAVERA, on behalf of himself ) Case No.: 1:15-cv-00105-AWI-BAM
and on behalf of all other similarly situated
)
individuals,
) STIPULATION FOR EXTENSION TO
Plaintiff,
) DISCOVERY CUT-OFF; ORDER
)
v.
)
)
LEPRINO FOODS COMPANY, a Colorado
)
Corporation; LEPRINO FOODS DAIRY
)
PRODUCTS COMPANY, a Colorado
)
Corporation; and DOES 1-50, inclusive,
)
Defendants.
)
-1–
Stipulation For Extension to Discovery Cut-Off; Order
Talavera v. Leprino Foods Company, et al., Case No. 1:15-cv-00105-AWI-BAM

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Whereas the Parties’ current non-expert discovery cut-off pursuant to the Court’s April 22,
2015 Preliminary Scheduling Order is December 15, 2015;
Whereas the Counsel for Defendant and Plaintiff have been engaged in a productive meet
and confer regarding the Parties’ respective responses to written discovery;
Whereas counsel for Defendant, primarily responsible for the informal discovery

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negotiations related to the Parties respective responses to written discovery, is unavailable and

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unreachable from September 17, 2015 to October 5, 2015 due to her wedding and honeymoon;

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Whereas the Parties have agreed to defer informal discovery negotiations and any
discovery motions until her return;
IT IS HEREBY STIPULATED AND AGREED by and between the parties and/or their

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respective counsels that they wish the current non-expert discovery cut-off date continued from

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December 15, 2015 to January 9, 2016. The parties have agreed that Plaintiff will not notice

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depositions to take place between December 24 and January 1. No further dates need be changed

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or continued because of this continuance.

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Therefore, the Parties request the Court continue the pending non-expert discovery cut-off
date from December 15, 2015 to January 9, 2016.

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Respectfully submitted,

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The Downey Law Firm, LLC

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/s/ Cory Lee
______________________________________
Cory Lee
Of Counsel
Counsel for the Plaintiff and the putative class

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Dated: September _22, 2015
HANSON BRIDGETT LLP

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/s/Sandra L. Rappaport_
_
Sandra L. Rappaport
Counsel for Defendants Leprino Foods Company and
Leprino Foods Dairy Products Company

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Dated: September 22, 2015
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Stipulation For Extension to Discovery Cut-Off; Order
Talavera v. Leprino Foods Company, et al., Case No. 1:15-cv-00105-AWI-BAM

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ORDER

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Based upon the stipulation of the parties, and for good cause shown, IT IS HEREBY

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ORDERED that the pending non-expert discovery cut-off deadline is continued from December

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15, 2015 to January 9, 2016.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

September 23, 2015

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE

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_

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Stipulation For Extension to Discovery Cut-Off; Order
Talavera v. Leprino Foods Company, et al., Case No. 1:15-cv-00105-AWI-BAM