Medina v. National Oilwell Varco, L.P.

Filing 36

Joint STIPULATION to Continue Trial Date and Related Case Deadlines; ORDER, signed by District Judge Dale A. Drozd on 5/2/2016. (The trial date and related case deadlines are continued as follows- Fact Discovery Cutoff: 8/19/2016, Dispositive Motio n Filing Deadline: 9/20/2016, Dispositive Motion Hearing Deadline: 10/18/2016 at 9:30am, Expert Disclosures: 8/26/2016, Supplemental Expert Disclosures: 9/23/2016, Expert Discovery Cutoff: 10/26/2016, Pretrial Conference is continued to 12/19/2016, at 02:30 PM in Courtroom 5 (DAD) before District Judge Dale A. Drozd, and Jury Trial is continued to 2/14/2017, at 08:30 AM in Courtroom 5 (DAD) before District Judge Dale A. Drozd.) (Gaumnitz, R)

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Michael J.F. Smith, Esq.
John L Migliazzo, Esq.
1391 West Shaw Avenue, Ste. D
Fresno, CA 93711
Telephone: [phone]
Attorneys for Plaintiff,
JORGE MEDINA

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Christian Keeney, CA Bar No. 269533
[e-mail]
Natalie R. Alameddine CA Bar No. 296423
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Park Tower, Suite 1500
695 Town Center Drive
Costa Mesa, CA 92626
Telephone:
714.800.7900
Facsimile:
714.754.1298
Attorneys for Defendant
DNOW, L.P.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JORGE MEDINA, an individual
Plaintiff,

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vs.

Case No. 1:15-CV-00235-DAD-JLT
Assigned to:
District Judge Dale A. Drozd
Magistrate Judge Jennifer L. Thurston

DNOW, L.P. and DOES 1 through 10, inclusive JOINT STIPULATION TO CONTINUE
TRIAL DATE AND RELATED CASE
Defendant.
DEADLINES; ORDER

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TO THE ABOVE HONORABLE COURT:

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Plaintiff JORGE MEDINA (“Plaintiff”) and Defendant DNOW, L.P. (“Defendant”)

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(collectively the “Parties”), agree as follows:

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1.

The parties agree that good cause exists to continue the trial date and related

deadlines for the following reason(s).

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2.

The deadline to complete fact discovery is April 29, 2016 and the deadline to file

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dispositive motions is July 1, 2016. Through no fault of either party, Defendant has been unable to

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complete depositions it must conduct in advance of these deadlines, including the deposition of

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Michelle Owens, who submitted a written statement purportedly in support of Plaintiff’s

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allegations and failed to appear for her deposition.

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3.

The parties agree that neither party will be prejudiced by the stipulated continuance.

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4.

Accordingly, the parties request that the trial date and related case deadlines be

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continued as follows:

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Event

Current Deadline

New Deadline

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Fact Discovery Cutoff

April 29, 2016

August 19, 2016

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Dispositive Motion Filing Deadline

May 17, 2016

September 20, 2016

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Dispositive Motion Hearing Deadline

July 1, 2016

October 18, 2016

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Expert Disclosures

May 12, 2016

August 26, 2016

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Supplemental Expert Disclosures

June 7, 2016

September 23, 2016

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Expert Discovery Cutoff

July 6, 2016

October 26, 2016

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Final Pretrial Conference

September 26, 2016

December 19, 2016

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Trial

November 15, 2016

February 14, 2017

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5.

Any dates or deadlines not expressly referenced above will be continued by the

same number of days as the trial date is continued.

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6.

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this matter.

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This is the first time that the parties have requested a continuance of the trial date in

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DATED: April 29, 2016

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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By: /s/ Natalie R. Alameddine
Christian Keeney
Natalie R. Alameddine

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Attorneys for Defendant
DNOW, L.P.

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DATED: April 29, 2016
By: /s/ John L Migliazzo
(as authorized on April 29, 2016)
Michael J.F. Smith
John L Migliazzo
Attorneys for Plaintiff
JORGE MEDINA

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ORDER
Upon consideration of the Parties’ Joint Stipulation to Continue Discovery and Dispositive

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Motions Deadlines, and good cause appearing,

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IT IS HEREBY ORDERED THAT:

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1.

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Event

Current Deadline

New Deadline

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Fact Discovery Cutoff

April 29, 2016

August 19, 2016

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Dispositive Motion Filing Deadline

May 17, 2016

September 20, 2016

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Dispositive Motion Hearing Deadline

July 1, 2016

October 18, 2016

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Expert Disclosures

May 12, 2016

August 26, 2016

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Supplemental Expert Disclosures

June 7, 2016

September 23, 2016

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Expert Discovery Cutoff

July 6, 2016

October 26, 2016

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Final Pretrial Conference

September 26, 2016

December 19, 2016

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Trial

November 15, 2016

February 14, 2017

The trial date and related case deadlines be continued as follows:

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2.

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Any dates or deadlines not expressly referenced above will be continued by the

same number of days as the trial date is continued.

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IT IS SO ORDERED.
Dated:

May 2, 2016
UNITED STATES DISTRICT JUDGE

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