Cenis v. WinCo Holdings, Inc. et al

Filing 52

STIPULATION and ORDER 51 to Continue Expert Discovery Deadlines, signed by Magistrate Judge Jennifer L. Thurston on 3/12/2018. Expert discovery cutoff 5/25/2018. (Hall, S)

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SEYFARTH SHAW LLP
Kristina M. Launey (SBN 221335)
[e-mail]
Tiffany T. Tran (SBN 294213)
[e-mail]
400 Capitol Mall, Suite 2350
Sacramento, CA 95814
Telephone:
[phone]
Facsimile:
[phone]
SEYFARTH SHAW LLP
Ari Hersher (SBN 260321)
[e-mail]
560 Mission Street, 31st Floor
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
WINCO HOLDINGS, INC.

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BONONI LAW GROUP, LLP
Michael J. Bononi (SBN 130663)
[e-mail]
Christy W. Granieri (SBN 266392)
[e-mail]
915 Wilshire Blvd, Suite 1950
Los Angeles, CA 90017
Phone: [phone]
Attorneys for Plaintiff
WENDY CENIS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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WENDY CENIS,

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Case No. 1:17-cv-00863-DAD-JLT
Plaintiff,

v.
WINCO HOLDINGS, INC., a corporation;
BRANDON RODGERS, an individual;
and DOES 1 through 25, inclusive.

JOINT STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
EXPERT DISCOVERY DEADLINES
(Doc. 51)

Defendants.

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCOVERY DEADLINES /
CASE NO. 1:17-CV-00863-DAD-JLT

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Pursuant to Federal Rule of Civil Procedure Rule 26, Plaintiff Wendy Cenis and Defendant

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WinCo Holdings, Inc. jointly submit this stipulation to continue expert discovery deadlines in this

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matter. Good cause exists for the continuance as follows:

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WHEREAS, the parties filed Cross-Motions for Summary Judgment (“Cross-MSJs”), which
were both heard before Judge Drozd on December 19, 2017;

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WHEREAS, the Court entered a Scheduling Order setting expert discovery deadlines as follows:

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

The parties disclose expert on or before November 3, 2017;

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

The parties disclose rebuttal experts on or before December 11, 2017;

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

The parties complete all expert discovery on or before December 29, 2017;

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WHEREAS, the parties stipulated to continue expert discovery deadlines to allow the Court to

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rule on the parties’ Cross-MSJs prior to the parties’ incurring additional litigation costs that would be

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rendered moot pending the Court’s rulings on the Cross-MSJs;

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WHEREAS, the Court ordered the case schedule amended as follows:

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

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The parties disclose experts no later than three weeks after the Court rules on the CrossMSJS but in no event shall experts be disclosed later than March 16, 2018;

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

Rebuttal experts shall be disclosed three weeks thereafter but no later than April 6, 2018;

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

Expert discovery shall be completed four weeks after the deadline for disclosure of

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rebuttal experts but no later than May 4, 2018;

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WHEREAS, the Court has not yet issued rulings on the parties’ Cross-MSJs;

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WHEREAS, the parties agree that a further continuance of expert discovery deadlines will allow

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the Court additional time to rule on the parties- Cross-MSJs and prevent unnecessary costs associated

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with expert discovery in the event the Court dismisses some, or all, of Plaintiff’s claims;

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WHEREFORE, the parties jointly request that the Court continue the expert discovery deadlines
as follows:


The parties disclose expert on or before April 20, 2018;

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

The parties disclose rebuttal experts on or before May 2, 2018;

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

The parties complete all expert discovery on or before May 25, 2018.

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCLOSURES DEADLINE/
CASE NO. 1:17-CV-00863-DAD-JLT

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Respectfully submitted
Dated: March 12, 2018

SEYFARTH SHAW LLP

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By:

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/s/ Tiffany T. Tran
Kristina M. Launey
Ari Hersher
Tiffany T. Tran

Attorneys for Defendants
WINCO HOLDINGS, INC.

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Dated: March 6, 2018

BONONI LAW GROUP, LLP

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By: /s/ Christy W. Granieri
Michael J. Bononi
Christy W. Granieri
Attorneys for Plaintiff
WENDY CENIS

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Attorney for Plaintiff agreed with the contents of
this document and authorized the filer to use her
electronic signature.

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCOVERY DEADLINES /
CASE NO. 1:17-CV-00863-DAD-JLT

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING, IT IS SO
ORDERED that the current expert discovery deadlines be continued as follows:

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•

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The parties disclose rebuttal experts on or before May 2, 2018;

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The parties disclose expert on or before April 20, 2018;

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The parties complete all expert discovery on or before May 25, 20181.

The parties are advised that, regardless of whether the motion for summary judgment is decided,
no further extensions of time will be granted related to expert discovery.

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IT IS SO ORDERED.

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Dated:

March 12, 2018

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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In granting this stipulation, the Court assumes the parties are aware that there is no extension of time sought or granted
related to non-dispositive motions.

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCOVERY DEADLINES /
CASE NO. 1:17-CV-00863-DAD-JLT