Johnson v. Republic Services, Inc. et al

Filing 21

JOINT STIPULATION and ORDER to continue Non-trial discovery related dates, signed by Magistrate Judge Michael J. Seng on 9/28/2016. (Kusamura, W)

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ERIC C. BELLAFRONTO, Bar No. 162102
JOSE MACIAS, JR., Bar No. 265033
LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
Telephone: [phone]
Facsimile: 408.288.5686
Attorneys for Defendants
REPUBLIC SERVICES, INC. AND
ALLIED WASTE SERVICES OF NORTH
AMERICA, LLC
ERIC P. OREN, Bar No. 106129
LAW OFFICES OF ERIC P. OREN, INC.
225 West Shaw Avenue, Suite 105
Kern, California 93704
Tel: [phone] (Kern)
Tel: [phone] (Bakersfield)
Facsimile: [phone]
Attorneys for Plaintiff, CHARLES
JOHNSON

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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CHARLES JOHNSON,
Plaintiff,

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v.

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REPUBLIC SERVICES, INC.,
ALLIED WASTE SERVICES OF
NORTH AMERICA, LLC and
DOES 1 through 50, inclusive,

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Defendant.

Case No. 1:15-cv-01447-DAD-MJS
JOINT STIPULATION TO
CONTINUE NON-TRIAL
DISCOVERY RELATED DATES
AND [PROPOSED] ORDER
THEREON
Magistrate Judge: Michael Seng
Judge: Hon. Dale A. Drozd

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LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
408.998.4150

JOINTT STIPULATION TO CONTINUE
DISCOVERY DATES

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(Case No. 1:15-cv-01447-DAD-MJS)

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Plaintiff Charles Johnson (“Plaintiff”), on the one hand, and Defendants

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Republic Services, Inc. and Allied Waste Services of North America, LLC

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(“Defendants”) on the other, by and through their respective counsel of record, hereby

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stipulate and agree as follows:

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WHEREAS, on March 31, 2016, a Scheduling Conference was held and

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dates were set including a discovery cut off, expert disclosure deadlines, non-

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dispositive and dispositive motion deadlines, a Final Pretrial Conference on April 10,

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2017, and a five day Jury Trial on May 31, 2017;

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WHEREAS, the Parties have been diligently engaging in written

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discovery and plan on taking the depositions of Plaintiff and additional Company

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witnesses of Defendants in October of 2016;

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WHEREAS, the Parties would like a short continuance of approximately

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six (6) weeks on all discovery-related deadlines in order to allow them to adequately

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complete discovery;
WHEREAS, the requested short continuance will not impact the hearing

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date on any dispositive motions, the Final Pretrial Conference or Jury Trial date;
WHEREAS, counsel for the Parties are working collaboratively to move

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the case along efficiently;
WHEREAS, no prior continuances have been granted in this matter and

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no party will suffer prejudice as a result of the proposed short continuance;
NOW, THEREFORE, Plaintiff and Defendants, by and through their

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attorneys of record, hereby stipulate that the below dates be continued as follows:

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EVENT

OLD DEADLINE

NEW DEADLINE

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Non-Expert Discovery Cutoff

October 18, 2016

November 29, 2016

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Expert Discovery Cutoff

November 18, 2016

December 30, 2016

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Expert Disclosure Filing

October 1, 2016

November 11, 2016

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Expert Disclosure Rebuttal

October 18, 2016

November 29, 2016

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LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
408.998.4150

JOINTT STIPULATION TO
DISCOVERY DATES

CONTINUE

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(Case No. 1:15-cv-01447-DAD-MJS)

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IT IS SO STIPULATED.

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DATED: September 28, 2016

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/s/ Eric P. Oren
ERIC P. OREN
Attorney for Plaintiff,
CHARLES JOHNSON
Respectfully submitted,

DATED: September 28, 2016

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/s/ Eric C. Bellafronto
ERIC C. BELLAFRONTO
JOSE MACIAS, JR.
Attorneys for Defendants,
REPUBLIC SERVICES, INC. AND
ALLIED WASTE SERVICES OF NORTH
AMERICA, LLC

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LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
408.998.4150

JOINTT STIPULATION TO
DISCOVERY DATES

CONTINUE

3.

(Case No. 1:15-cv-01447-DAD-MJS)

ORDER

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Counsel for the Parties in the above-captioned action submitted a Joint

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Stipulation to Continue all Non-Trial Discovery Related Deadlines.
After consideration of the papers submitted, and good cause appearing

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therefore, it is hereby ORDERED that, the below deadlines be continued as follows:

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EVENT

OLD DEADLINE

NEW DEADLINE

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Non-Expert Discovery Cutoff

October 18, 2016

November 29, 2016

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Expert Discovery Cutoff

November 18, 2016

December 30, 2016

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Expert Disclosure Filing

October 1, 2016

November 11, 2016

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Expert Disclosure Rebuttal

October 18, 2016

November 29, 2016

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IT IS SO ORDERED.
Dated:

September 29, 2016

/s/

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Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
408.998.4150

JOINTT STIPULATION TO
DISCOVERY DATES

CONTINUE

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(Case No. 1:15-cv-01447-DAD-MJS)