Medina v. National Oilwell Varco, L.P.

Filing 38

STIPULATION and ORDER to Continue Dispositive Motion Hearing Deadline, signed by District Judge Dale A. Drozd on 9/15/2016. (The dispositive motion hearing deadline is continued from October 18, 2016, to October 31, 2016.)(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 STIPULATION AND ORDER TO
CONTINUE DISPOSITIVE MOTION
Defendant.
HEARING DEADLINE

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State Action Filed: December 18, 2014
Trial Date:
February 14, 2017

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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, subject to the Court’s approval, to continue the deadline to hear

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dispositive motions in this matter by 14 days from October 18, 2016 to November 1, 2016, based

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on the following:

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Defendant plans to file a motion for summary judgment.

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The current deadline to hear dispositive motions in this case is October 18, 2016.

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Good cause exists for the requested continuance because Defendant’s counsel is required to

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be out of town on another client matter between October 17, 2016 and October 19, 2016 and thus

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will be unavailable for hearing on October 18, 2016.

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The Court only hears civil motions on the first and third Tuesday of each month. As such,

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the next date on which Defendant’s motion for summary judgment may be heard is November 1,

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2016.

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The trial in this matter is not scheduled to begin until February 14, 2017.

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

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Accordingly, the parties respectfully request that the Court continue the dispositive motion
hearing deadline from October 18, 2016 to November 1, 2016.

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DATED: September 15, 2016

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

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

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Attorneys for Defendant
DNOW, L.P.

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DATED: September 15, 2016

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By: /s/ John L. Migliazzo
(as authorized on September 15, 2016)
Michael J.F. Smith
John L Migliazzo

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Attorneys for Plaintiff
JORGE MEDINA

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///

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///

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

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Hearing Deadline, and good cause appearing therefor, the Court orders that:

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The dispositive motion hearing deadline is continued from October 18, 2016, to October
31, 2016.

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IT IS SO ORDERED.
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Dated:

September 15, 2016
UNITED STATES DISTRICT JUDGE

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