U.S. Equal Employment Opportunity Commission v. Sensient Dehydrated Flavors Company, et al.

Filing 51

Joint STIPULATION and ORDER to Extend Preliminary Scheduling Order Deadline: (1.) All stipulated amendments or motions to amend the Complaint to name SNI as the sole corporate Defendant shall be filed by September 2, 2016. The August 5, 2016 deadline for amending or filing a stipulated amendment to the pleadings remains in effect for all other purposes. signed by Magistrate Judge Barbara A. McAuliffe on 8/8/2016. (Herman, H)

Anna Y. Park, CA SBN 164242

1 Sue Noh, CA SBN 192134
2 Rumduol Vuong, CA SBN 264392

Jennifer L. Boulton, CA SBN 259076

3 Lorena Garcia Bautista, CA SBN 234091
Eric Yau, CA SBN 275457

4 U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

5 255 East Temple Street, Fourth Floor
6 Los Angeles, CA 90012
Telephone: [phone]

7 Facsimile: [phone]
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Email: [e-mail]

Carlos Jauregui, SBN 280492
9 Juan EQUAL EMPLOYMENT
U.S.
10 OPPORTUNITY COMMISSION
2300 Tulare Street, Suite 215

11 Fresno, CA 93721
Telephone: [phone]

12 Facsimile: [phone]
13 E-Mail: [e-mail]
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Attorneys for Plaintiff
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

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LITTLER MENDELSON, P.C.

16 Kevin V. Koligian, Bar No. 258711
17 Natalie M. Jansen, Bar No. 286401
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5200 North Palm Avenue, Suite 302
Fresno, CA 93704-2225
Telephone:
559.244.7500
Facsimile:
559.244.7525
E-mail:[e-mail]
[e-mail]
MICHAEL BEST & FRIEDRICH LLP
Amy Schmidt Jones (admitted pro hac vice)
Anne M. Carroll (admitted pro hac vice)
100 East Wisconsin Avenue, Suite 3300
Milwaukee, WI 53202-4108
Telephone:
414.271.6560
Facsimile:
414.277.0656
E-mail: [e-mail]
[e-mail]

Brian P. Paul (admitted pro hac vice)

1 Two Prudential Plaza
2 180 North Stetson Avenue
Suite 2000

3 Chicago, IL 60601
Telephone:

312.222.0800
312.222.0818
E-mail: [e-mail]

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6 Attorneys for Defendant

Sensient Natural Ingredients LLC

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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9 U.S. EQUAL EMPLOYMENT

Case No. 1:15- CV-01431-DAD-BAM

OPPORTUNITY COMMISSION,

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Plaintiff,
v.

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SENSIENT DEHYRDRATED FLAVORS

13 COMPANY, et al., Does 1 - 10 inclusive,
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Defendants.

JOINT STIPULATION AND [PROPOSED]
ORDER TO EXTEND PRELIMINARY
SCHEDULING ORDER DEADLINE

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Plaintiff United States Equal Employment Opportunity Commission (“EEOC” or

2 “Plaintiff”) and Defendant Sensient Natural Ingredients LLC (incorrectly identified in the
3 Complaint as “Sensient Natural Ingredients, LLC”) (“SNI”), f/k/a Sensient Dehydrated Flavors
4 LLC (incorrectly identified in the Complaint as “Sensient Dehydrated Flavors, LLC”), and
5 successor in interest to Sensient Dehydrated Flavors Company (“Defendant”), through their
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respective counsel of record, hereby stipulate pursuant to Rule 16 of the Federal Rules of Civil
Procedure as follows:
1. Good Cause to Extend Preliminary Scheduling Order Deadline

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The parties come before the Court to seek an extension of the Preliminary Scheduling

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Order deadline to amend the parties’ pleadings by stipulation solely as to the naming of the

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proper Defendant. Specifically, the parties seek an extension to reach an agreement as to the
naming of SNI as the sole Defendant. While the parties have not yet agreed to a stipulation, the
parties have met and conferred and documents have been provided outside of the formal

13 discovery process. The parties currently are working on the terms of the stipulation. The EEOC
14 has requested additional time to negotiate a stipulation, and SNI does not oppose a four-week
15 extension (i.e. 28 days) to permit the parties to reach an agreement with respect to the naming of
16 SNI as the sole Defendant and to amend the Complaint accordingly. As such, the parties request
17 that the Court, for good cause, grant the parties’ request for an extension of time for the sole
18 purpose of filing a stipulated amendment to the Complaint to name SNI as the sole corporate
19 Defendant.
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2. Stipulation to Amend Preliminary Scheduling Order

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The parties stipulate that the Preliminary Scheduling Order be amended to reflect the

22 following new deadline:
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1. All stipulated amendments or motions to amend the Complaint to name SNI as the

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sole corporate Defendant shall be filed by September 2, 2016. The August 5, 2016

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deadline for amending or filing a stipulated amendment to the pleadings remains in

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effect for all other purposes.

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IT IS SO STIPULATED.
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

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Date: August 8, 2016

By:

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/s/ Jennifer L. Boulton
Jennifer L. Boulton
Attorney for Plaintiff U.S. EEOC

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MICHAEL BEST & FRIEDRICH LLP

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Date: August 8, 2016

By:

/s/ Amy Schmidt Jones_________
Amy Schmidt Jones
Attorney for Defendant Sensient Natural
Ingredients LLC

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ORDER

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For good cause shown, the stipulation to extend the Preliminary Scheduling Order

4 deadline is hereby approved and the new deadline for amendment to the parties’ pleadings as set
5 forth in the Preliminary Scheduling Order shall be amended as follows:
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1.

All stipulated amendments or motions to amend the Complaint to name SNI as the
sole corporate Defendant shall be filed by September 2, 2016. The August 5, 2016
deadline for amending or filing a stipulated amendment to the pleadings remains in
effect for all other purposes.

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IT IS SO ORDERED.

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13 Dated: August 8, 2016
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/s/ Barbara

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE