Saniefar v. Moore et al

Filing 146

JOINT STIPULATION and ORDER to Modify Scheduling Order signed by Magistrate Judge Barbara A. McAuliffe on 5/6/2019. (Sant Agata, S)

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MOJI SANIEFAR, Cal. Bar. No. 233330
SANIEFAR LAW
7469 Mission St., 2nd Fl.
Daly City, CA 94014
Tel: [phone]
[e-mail]
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
Including Professional Corporations
RAYMOND C. MARSHALL, Cal. Bar No. 83717
GREGORY F. HURLEY, Cal. Bar No. 126791
WHITNEY A. HODGES, Cal. Bar No. 273080
[e-mail]
[e-mail]
[e-mail]
650 Town Center Drive, 4th Floor
Costa Mesa, California 92626-1993
Telephone:
714.513.5100
Facsimile:
714.513.5130
Attorneys for Plaintiff FATEMEH SANIEFAR

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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FATEMEH SANIEFAR,

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Plaintiff,

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Case No. 1:17-cv-00823-LJO-BAM
JOINT STIPULATION AND ORDER TO
MODIFY SCHEDULING ORDER

vs.
RONALD D. MOORE, TANYA E. MOORE,
KENNETH RANDOLPH MOORE,
MAREJKA SACKS, ELMER LEROY FALK,
ZACHARY M. BEST, MOORE LAW FIRM,
a California Professional Corporation,
MISSION LAW FIRM, a California
Professional Corporation, GEOSHUA
LEVINSON, RICK D. MOORE, WEST
COAST CASP AND ADA SERVICES, a
California Corporation, RONNY LORETO,
and DOES 1 THROUGH 100, inclusive,

District Judge: Hon. Lawrence J. O’Neil
Magistrate Judge: Hon. Barbara A. McAuliffe

Defendants.

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STIPULATION MODIFYING SCHEDULING ORDER AND ORDER

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Plaintiff Fatemeh Saniefar and Defendants Ronald D. Moore, Tanya E. Moore,

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Kenneth Randolph Moore, Marejka Sacks, Zachary M. Best, Moore Law Firm, Mission Law

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Firm, Geoshua Levinson, Rick D. Moore, West Coast CASp and ADA Services, and Ronny

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Loreto, by and through their undersigned counsel, hereby submit the following Stipulation

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Modifying Scheduling Order to modify the Court’s Scheduling Order issued on July 24, 2018 for

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good cause for the stated reasons below.
WHEREAS, the Court issued a Scheduling Order on July 24, 2018 with the following

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deadlines:
Expert Disclosures - May 17, 2019;

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Non-expert Discovery Cutoff - June 7, 2019;

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Supplemental Expert Disclosures - June 21, 2019;

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Expert Discovery Cutoff - August 9, 2019;

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Pretrial Motion Filing Deadline - October 4, 2019;

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Pretrial Conference - March 3, 2020; and

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Trial - May 5, 2020;

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Whereas, pursuant to the Court’s order of April 23, 2019, Defendants have been ordered

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to produce a privilege log and unprivileged and responsive documents to Plaintiff by May 23,

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2019;

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Whereas, after Defendants produce documents and a privilege log as ordered by April

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23, 2019, Plaintiff intends to pursue a motion to compel based on application of the crime-fraud

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exception;

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Whereas, the Parties are still in the midst of conducting fact discovery;

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Whereas, because of ongoing discovery, under the Court’s current Scheduling Order, the

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Parties will be unable to: (1) provide their expert disclosures by May 17, 2019; (2) finish fact

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discovery by June 7, 2019; (3) provide supplemental expert disclosures by June 21, 2019; and

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finish expert discovery by August 9, 2019.

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THEREFORE, the parties agree that good cause exists to extend the following deadlines
as provided below:
STIPULATION MODIFYING SCHEDULING ORDER AND ORDER

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Expert Disclosures - August 16, 2019;

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Non-expert Discovery Cutoff - September 6, 2019;

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Supplemental Expert Disclosures - September 13, 2019;

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Expert Discovery Cutoff – October 11, 2019;

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Pretrial Motion Filing Deadline – November 22, 2019;

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All remaining dates issued in the July 24, 2018 Scheduling Order are to remain

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unchanged, or to other dates that the Court deems appropriate based on the Court’s scheduling

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preference.
Respectfully submitted,

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DATED: May 6, 2019

SANIEFAR LAW
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

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/s/ Moji Saniefar
MOJI SANIEFAR
RAYMOND C. MARSHALL
GREGORY F. HURLEY
WHITNEY A. HODGES
Attorneys for Plaintiff Fatemeh Saniefar

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DATED: May 6, 2019

GORDON REES SCULLY MANSUKHANI, LLP

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/s/ Steven R. Inouye
Roger M. Mansukhani
David L. Jones
Steven R. Inouye
Attorneys for Defendants
Moore Law Firm, A.P.C., Tanya E. Moore, Kenneth
Randolph Moore, Ronald D. Moore, Zachery M. Best,
Marejka Sacks, Mission Law Firm, A.P.C., Elmer Leroy
Falk, Geoshua Levinson, Rick D. Moore, West Coast
CASp and ADA Services, and Ronny Loreto

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STIPULATION MODIFYING SCHEDULING ORDER AND ORDER

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ORDER

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Based on the Joint Stipulation of the parties, and good cause appearing therefor, IT

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IS ORDERED that the Scheduling Order issued on July 24, 2018 be modified as follows:

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Expert Disclosures - August 16, 2019;

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Non-expert Discovery Cutoff - September 6, 2019;

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Supplemental Expert Disclosures - September 13, 2019;

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Expert Discovery Cutoff – October 11, 2019;

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Pretrial Motion Filing Deadline – November 22, 2019;
All remaining dates issued in the July 24, 2018 Scheduling Order are to remain

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unchanged.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

May 6, 2019

A. McAuliffe

_

UNITED STATES MAGISTRATE JUDGE

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STIPULATION MODIFYING SCHEDULING ORDER AND ORDER

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