Mission Linen Supply v. City of Visalia

Filing 25

Stipulation and third joint request for extension of time regarding close of non expert discovery and expert discovery and Order, signed by Magistrate Judge Erica P. Grosjean on 5/12/2016. (Non-Expert Discovery Deadline: 6/15/2016; Expert Disclosure due by 7/27/2016; Expert Discovery due by 9/12/2016) (Rosales, O)

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LORI J. GUALCO (Bar No. 95232)
GUALCO LAW
400 Capitol Mall, Eleventh Floor
Sacramento, CA 95814
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff
MISSION LINEN SUPPLY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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MISSION LINEN SUPPLY,
Plaintiff,

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STIPULATION AND THIRD JOINT
REQUEST FOR EXTENSION OF TIME
REGARDING CLOSE OF NONEXPERT DISCOVERY AND EXPERT
DISCOVERY AND ORDER

Defendant.

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Case No. 1:15-cv-00672-AWI-EPG

Date Complaint Filed: May 1, 2015
Trial Date: December 13, 2016

v.
CITY OF VISALIA,

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Plaintiff Mission Linen Supply (“Plaintiff Mission”), by and through its attorney of
record, Gualco Law and Lori J. Gualco, and Defendant City of Visalia (“Defendant City”), by

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and through its attorneys of record, Herr, Pedersen & Berglund LLP and Leonard C. Herr,

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having met and conferred on the issue of moving the following discovery dates listed in numbers

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1 through 4 below, hereby stipulate and agree that good cause exists for a third extension of

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discovery dates in this case. The stipulation and request for order granting a first extension of

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discovery dates was submitted on February 5, 2016 and an order was signed and filed on

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

February 8, 2016. The stipulation and request for order granting a second extension of discovery
dates was submitted on April 7, 2016 and an order was signed on April 12, 2016 and filed on
April 13, 2016. Defendant City’s FRCP Rule 30(b)(6) witnesses were coordinated for a joint
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STIPULATION AND THIRD JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT
DISCOVERY AND ORDER

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deposition with the parties in the case entitled Coppola v. Paragon Cleaners, Inc., et al., Case

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No.1:11-CV-01257-AWI-BAM.

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Due to discovery being coordinated in this case and with the Coppola v. Paragon
Cleaners, Inc., et al. case for the depositions of Defendant City’s Rule 30(b)(6) witnesses, and

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those depositions being conducted the last week of April 2016, the parties have experienced a

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delay in the scheduling of several additional specified Defendant City depositions to be taken in

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this case and jointly in the Coppola v. Paragon Cleaners, Inc., et al. case.

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The Plaintiff Mission and Defendant City agree that the extended discovery dates shall
be as follows:
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Date of Non-Expert Discovery Cutoff extended from May 15, 2016 to June 15,

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2016 for the depositions of the following witnesses to be conducted: Defendant

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City of Visalia employees Jim Ross, Mike Olmos and Richard Paradez, and Brian

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Vanciel, a former employee of the City of Visalia, to be conducted jointly with

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the taking of these depositions in the Coppola v. Paragon Cleaners, Inc. et al.

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case;

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2.

Date of Initial Expert Disclosure extended from July 6, 2016 to July 27, 2016;

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Date of Rebuttal Expert Disclosure extended from August 16, 2016 to August 30,

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2016; and

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4.

Date of Expert Discovery Cutoff extended from August 29, 2016 to September
12, 2016.

Plaintiff Mission and Defendant City jointly move for an order regarding the above dates.

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Dated: May 11, 2016

GUALCO LAW

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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STIPULATION AND THIRD JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT
DISCOVERY AND ORDER

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By: /s/ Lori J. Gualco
LORI J. GUALCO
Attorney for Plaintiff MISSION LINEN
SUPPLY

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Dated: May 11, 2016

HERR PEDERSEN & BERGLUND LLP

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By: /s/ Leonard C. Herr, as authorized on 5-11-16
Leonard C. Herr
Ron Statler
Attorneys for Defendant CITY OF VISALIA

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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STIPULATION AND THIRD JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT
DISCOVERY AND ORDER

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ORDER

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Based on the above Joint Stipulation of Plaintiff Mission Linen Supply and Defendant
City of Visalia, the extended dates for discovery are as follows:

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1.

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Date of Non-Expert Discovery Cutoff extended from May 15, 2016 to June 15,

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2016 for the depositions of the following witnesses to be conducted: Defendant

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City of Visalia employees Jim Ross, Mike Olmos and Richard Paradez, and Brian

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Vanciel, a former employee of the City of Visalia, to be conducted jointly with

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the taking of these depositions in the Coppola v. Paragon Cleaners, Inc. et al.

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case;

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2.

Date of Initial Expert Disclosure extended from July 6, 2016 to July 27, 2016;

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Date of Rebuttal Expert Disclosure extended from August 16, 2016 to August 30,

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2016; and

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4.

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12, 2016.

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Date of Expert Discovery Cutoff extended from August 29, 2016 to September

All other dates set forth in the scheduling order (ECF No. 11) remain unchanged,
including the deadline for the filing of dispositive motions, the pretrial conference date, and trial

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date.

The Court notes that this stipulation constitutes the fourth stipulation to amend the

scheduling order that the parties have filed. The parties are thus advised that further requests to
modify the scheduling order will be viewed with disfavor.

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IT IS SO ORDERED.

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Dated:

May 12, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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STIPULATION AND THIRD JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT
DISCOVERY AND ORDER