Stinchecum et al v. Dollar General Corp.

Filing 19

STIPULATION and ORDER TO EXTEND DEADLINE FOR NON-EXPERT DISCOVERY CUTOFF, signed by Magistrate Judge Michael J. Seng on 2/9/2018. (Kusamura, W)

1 Jeffrey M. Lenkov, Esq. (State Bar No. 156478)
[e-mail]
2 Alexandra R. Rambis, Esq. (State Bar No. 316460)
[e-mail]
3 MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
4 801 S. Figueroa St, 15th Floor
Los Angeles, California 90017-3012
5 Telephone: [phone]
Facsimile: [phone]
6
David V. Roth (State Bar No. 194648)
7
[e-mail]
MANNING & KASS
8 ELLROD, RAMIREZ, TRESTER LLP
333 Bush Street, 27th Floor
9 San Francisco, California 94104
Telephone: [phone]
10 Facsimile: [phone]
11 Attorneys for Defendant,
DOLLAR GENERAL CORP.
12
13

UNITED STATES DISTRICT COURT

14

EASTERN DISTRICT OF CALIFORNIA

15
16 JOHN STINCHECUM, an individual,
17
18

Case No. 1:17-cv-00240-DAD-MJS

Plaintiffs,
v.

19 DOLLAR GENERAL CORP. and DOES 1 to
25, Inclusive,
20
Defendants.
21

STIPULATION AND ORDER TO
EXTEND DEADLINE FOR NON-EXPERT
DISCOVERY CUTOFF

State Action Filed: December 5, 2016
Date of Removal: February 17, 2017

22
23
24

It is hereby STIPULATED by and between Plaintiff JOHN STINCHECUM (hereinafter

25 “Plaintiff”) and Defendant DOLLAR GENERAL CORP. (hereinafter “Defendant”), by and
26 through their counsel of record, as follows:
27

The Jury Trial in this matter is presently scheduled for September 11, 2018 at 8:30 a.m. in

28 Courtroom 5, before the Honorable Dale A. Drozd, United States District Court Judge.
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR NON-EXPERT DISCOVERY
CUTOFF

1

The Pretrial Conference in this matter is presently scheduled for July 9, 2018, at 1:30 p.m.,

2 in Courtroom 5, before the Honorable Dale A. Drozd, United States District Court Judge.
3

Parties have conferred and agreed that Good Cause exists for the Non-Expert Discovery

4 Cutoff set for March 2, 2018 to be continued as such dates would be premature as additional
5 discovery, including a Depositions of Defendant’s Person(s) Most Knowledgeable, and Defense
6 Medical Examination, must be completed in order for the parties to be prepared to proceed to trial.
7

NOW, THEREFORE, IT IS HEREBY AGREED AND STIPULATED by Plaintiffs and

8 Defendant, by and through their respective counsel, to request an Order that:
9

1.

Non-Expert Discovery Deadline be extended from March 2, 2018 to May 15, 2018.

10
11 DATED: February 6, 2018
12

MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP

13
By:

14
15
16
17
18 DATED: February 6, 2018

/S/ Alexandra R. Rambis, Esq.
Jeffrey M. Lenkov, Esq.
David V. Roth, Esq.
Alexandra R. Rambis, Esq.
Attorneys for Defendant,
DOLLAR GENERAL CORP.

WELEBIR TIERNEY, APLC.

19
20
21
22
23
24

By:

/S/ James F. Tierney, Esq.
James F. Tierney, Esq.
Douglas F. Welebir, Esq.
Attorneys for Plaintiffs
JOHN STINCHECUM and PETRA
STINCHECUM

25
26
27
28
2
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR NON-EXPERT DISCOVERY
CUTOFF

1
2
3

ORDER
Pursuant to the stipulation of the parties, it is hereby ORDERED that the nonExpert Discovery Deadline in Case No. 1:17-cv-00240-DAD-MJS is extended from

4 March 2, 2018 to May 15, 2018.
5
6 IT IS SO ORDERED.
7
8
9

Dated:

February 9, 2018

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR NON-EXPERT DISCOVERY
CUTOFF