Paula Gordon v. Nexstar Broadcasting, Inc., et al.

Filing 78

STIPULATION and ORDER 77 to Amend the Case Schedule, signed by Magistrate Judge Jennifer L. Thurston on 2/5/2019. Depositions of Chase and Underwood completed by 2/22/2019. Expert discovery completed by 5/13/2019. Non-Dispositive Motion Deadlines: Filed by 5/17/2019; Hearing by 6/14/2019. (Hall, S)

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Dylan B. Carp (State Bar No. 196846)
Angel R. Sevilla (State Bar No. 239072)
Stephanie T. Yang (State Bar No. 280006)
JACKSON LEWIS P.C.
50 California Street, 9th Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant
NEXSTAR BROADCASTING, INC.,

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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PAULA GORDON, an individual,

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Case No. 1:18-cv-00007-DAD-JLT
ORDER GRANTING STIPULATION
TO AMEND THE CASE SCHEDULE
(Doc. 77)

Plaintiff,

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v.

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NEXSTAR BROADCASTING, INC.
a business entity, form unknown; KGET-TV
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NETWORK, LLC, a business entity, form
unknown; TELEMUNDO 17.3, a business
entity, form unknown; ERIK MENDOZA, an
individual; and DOES 1 through 100, inclusive

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Defendants.

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To the Honorable Court:

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Pursuant to this Court’s Scheduling Order (Doc 58), the Parties, by stipulation, request an extension

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of the following discovery deadlines:

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•

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of

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February 22, 2019 to accommodate the availability of third party witness Adam Chase, a former

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Nexstar manager, who resides out of state and is only available for deposition on
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Fact Discovery Cutoff (solely for purposes of conducting the deposition and/or continuation
the

deposition

of

two

third

party

witnesses):

From

February

15,

2019

STIPULATION TO CONTINUE DEADLINES RELATED TO EXPERT DISCOVERY CUTOFF
Case No. 1:18-cv-00007-DAD-JLT

to

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February 18, 2019, and to complete the deposition of third party witness Allison Underwood, an

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outside investigator retained by Nexstar, which commenced on January 30 but could not be

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completed or rescheduled prior to the current February 15 discovery cutoff due to the schedules of

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the witness, her counsel and counsel for the parties. (Note: To the extent further motion practice

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is required with respect to Ms. Underwood, the Parties anticipate that a third deposition session

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may be required for Ms. Underwood.)

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•

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availability of Dr. Delia Silva to conduct a mental status examination of the Plaintiff.

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•

Rebuttal Expert Witness Disclosure: From March 22, 2019 to April 22, 2019

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Expert Discovery Cutoff: From April 12, 2019 to May 13, 2019 (May 12 is a Sunday).

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Good cause exists to grant the stipulation, as the Parties’ discovery timeline was constrained by the

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availability of a third party witness who resides out of state, by the inclement weather preventing

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the Parties’ completion of Plaintiff’s deposition prior to January 2019, the inability of another third

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party witness and her counsel as well as counsel for the parties to find a mutually available date for

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all parties for the completion of the deposition prior to the current non-expert discovery cutoff date,

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as well as by the proposed medical examiner’s lack of availability. This stipulation is supported

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by the declaration of Stephanie T. Yang, a copy of which is attached.

Expert Witness Disclosure: From March 1, 2019 to April 1, 2019, to accommodate the

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IT IS SO STIPULATED.

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Dated: February 1, 2019

JACKSON LEWIS P.C.

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By:

/s/ Stephanie T. Yang
Dylan B. Carp
Angel R. Sevilla
Stephanie T. Yang
Attorneys for Defendant
NEXSTAR BROADCASTING, INC.

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Dated: February 1, 2019

LAW OFFICES OF VICTOR L. GEORGE
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STIPULATION TO CONTINUE DEADLINES RELATED TO EXPERT DISCOVERY CUTOFF
Case No. 1:18-cv-00007-DAD-JLT

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By:

/s/ Wayne C. Smith
(as authorized on 1/28/19)
Victor L. George
Wayne C. Smith
Attorneys for Plaintiff
PAUL GORDON

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Dated: February 1, 2019

FISHER & PHILLIPS LLP

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By:

/s/ Cheryl Schreck
(as authorized on 01/28/19)
Todd B. Scherwin
Cheryl Schreck
Attorneys for Defendant
ERIK MENDOZA

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ORDER
Based upon the stipulation of the parties and good cause appearing, the Court ORDERS
the case schedule to be amended as follows:
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The depositions of Adam Chase, Allison Underwood SHALL be completed by

February 22, 2019;
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Experts SHALL be disclosed no later than April 1, 2019. Rebuttal experts may

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be disclosed no later than April 22, 2019 and all expert discovery SHALL be completed no later

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than May 13, 2019;

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3.

Any nondispositive motions SHALL be filed as soon as the need presents itself

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but no later than May 17, 2019 and heard no later than June 14, 2019.

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IT IS SO ORDERED.

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Dated:

February 5, 2019

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO CONTINUE DEADLINES RELATED TO EXPERT DISCOVERY CUTOFF
Case No. 1:18-cv-00007-DAD-JLT