Domingo v. Management & Training Corporation et al

Filing 71

STIPULATION and ORDER 70 to Set Settlement Conference and Modifying the Scheduling Order to Extend Time for Expert Discovery, signed by Magistrate Judge Jennifer L. Thurston on 2/16/2018. Expert Discovery Deadline 4/27/2018. Settlement Conference set for 3/5/2018 at 01:30 PM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston. (Hall, S)

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Susan E. Coleman (SBN 171832)
E-mail: [e-mail]
Kristina Doan Gruenberg (SBN 268188)
E-mail: [e-mail]
BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Tel: [phone] Fax: [phone]
Attorneys for Defendant
MANAGEMENT & TRAINING
CORPORATION

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LUIS C. DOMINGO,

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Plaintiff,

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v.

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MANAGEMENT & TRAINING
CORPORATION, AND JOHN
DOES
1 - 9.,

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STIPULATION AND [PROPOSED]
ORDER TO SET SETTLEMENT
CONFERENCE AND MODIFYING
SCHEDULING ORDER TO
EXTEND TIME FOR EXPERT
DISCOVERY
(Doc. 70)

Defendants.

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Case No. 1:15-cv-00284-AWI-JLT

Plaintiff Luis C. Domingo, and the Defendant Management & Training

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Corporation (“MTC”) (collectively “the parties”), by and through their respective

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counsel, respectfully submit this stipulation and proposed order setting a settlement

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conference for March 5, 2018, and modifying the scheduling order to allow expert

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discovery to extend beyond the dates currently set in the scheduling order. All

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parties have been engaging in settlement discussions, and are interested in resolving

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the case without incurring further attorneys’ fees or costs.

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Therefore, the parties request the assistance of the Honorable Jennifer L.

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Thurston to resolve these cases with a settlement conference at 10:00 a.m. on

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March 5, 2018, which date has been cleared with the Court.

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4841-1776-3165 v1

1:15-CV-00284-AWI-JWT
STIP TO SET SETTLEMENT CONF. AND
MODIFY SCHEDULING ORDER

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Additionally, in an effort to focus on settlement negotiations, the parties, by

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and through their respective counsel, stipulate and respectfully request the brief

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continuation of the expert dates outlined below. The proposed date changes will not

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affect the November 14, 2018 trial date. The current and proposed schedules are

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provided below for the Court’s reference.

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Current

Proposed

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Plaintiff’s Expert Disclosures

2/23/2018

3/9/2018

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Defendants’ Expert Disclosures

3/9/2018

3/23/2018

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Rebuttal Expert Disclosures

3/23/2018

4/2/18

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Dated: February

, 2018

BURKE, WILLIAMS & SORENSEN, LLP

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By:
Susan E. Coleman
Kristina Doan Gruenberg

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Attorneys for Defendant
MANAGEMENT & TRAINING
CORPORATION

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Dated: February

, 2018

BOUCHER, LLP

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By:
Hermez Moreno
Raymond Paul Boucher
Milin Chun
Brian M. Bush

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Attorneys for Plaintiff
LUIS C. DOMINGO

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///

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///

B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4841-1776-3165 v1

-2-

1:15-CV-00284-AWI-JWT
STIP TO SET SETTLEMENT CONF. AND
MODIFY SCHEDULING ORDER

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ORDER
Based upon the stipulation counsel, the Court ORDERS:
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The Court sets a settlement conference on March 5, 2018 at 1:30 p.m.;

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The case schedule is modified as follows:

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a.

Plaintiff’s expert disclosure: March 9, 2018;

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b.

Defendants’ expert disclosure: March 23, 2018;

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c.

Plaintiff’s rebuttal expert disclosure: April 2, 2018;

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d.

Expert discovery deadline: April 27, 2018

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IT IS SO ORDERED.
Dated:

February 16, 2018

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4841-1776-3165 v1

-3-

1:15-CV-00284-AWI-JWT
STIP TO SET SETTLEMENT CONF. AND
MODIFY SCHEDULING ORDER