Oliver v. Wong et al

Filing 83

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 4/14/2014 and agreed between the parties to CONTINUE the deadline to file the Joint/Separate Pretrial Statement and Joint Statement of Undisputed and Disputed Factual Issues to 5/19/2014. (Yin, K)

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SEYFARTH SHAW LLP
James D. McNairy (SBN 230903)
[e-mail]
Julie G. Yap (SBN 243450)
[e-mail]
400 Capitol Mall, Suite 2350
Sacramento, California 95814-4428
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff
JAMES OLIVER

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DEPARTMENT OF JUSTICE
Office of Attorney General of California
Kevin W. Reager (SBN 178478)
1300 I Street
P. O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
SCOTT CHESSER

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JAMES OLIVER,
Plaintiff,

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Case No. 2:08-cv-2524 LKK AC P
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE DEADLINE
TO FILE JOINT/SEPARATE
PRETRIAL STATEMENT AND JOINT
STATEMENT OF UNDISPUTED
FACTS AND DISPUTED FACTUAL
ISSUES

v.
SCOTT CHESSER,
Defendant.

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Judge: Hon. Allison Claire
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Plaintiff James Oliver and Defendant Scott Chesser, by and through their respective

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counsel of record, hereby submit the following stipulate to continue the deadline to file a

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Joint/Separate Pretrial Statement and the Joint Statement of Undisputed Facts and Disputed

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO FILE JOINT PRETRIAL
STATEMENT/SEPARATE STATEMENT
17111145v.1

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Factual Issues, from April 14, 2014 to May 19, 2014, because the Parties are in the process of

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negotiating and finalizing a settlement.

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WHEREAS, the Parties have been engaging in good faith settlement discussions;

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WHEREAS, the Parties have agreed to the monetary terms of the settlement;

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WHEREAS, the Parties have engaged in continued negotiations and made multiple

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revisions to the terms of a settlement agreement over the course of the last month;
WHEREAS, the Parties are working diligently to finalize the settlement agreement but do

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not anticipate that they will be able to file dispositional documents within 21 days in accordance

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with Local Rule 160 should a Notice of Settlement be filed today;

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IT IS SO STIPULATED that, in order to preserve resources, good cause exists to

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continue the deadline to file the Joint/Separate Pretrial Statement and Joint Statement of

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Undisputed and Disputed Factual Issues, from April 14, 2014 to May 19, 2014, because the

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parties are hopeful that a Notice of Settlement will be filed on or before that date and the Parties

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will file all dispositional documents 21 days from the Notice of Settlement in accordance with

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Eastern District Local Rule 160.

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Dated: April 14, 2014

SEYFARTH SHAW LLP

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By:

/s/ Julie G. Yap
James D. McNairy
Julie G. Yap
Attorneys for Plaintiff
JAMES OLIVER

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Dated: April 14, 2014

DEPARTMENT OF JUSTICE
Office of the Attorney General of California

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By: /s/ Kevin Reager
Kevin Reager
Attorneys for Defendant
SCOTT CHESSER

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IT IS SO ORDERED.
DATED: April 14, 2014

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO FILE JOINT PRETRIAL
STATEMENT/SEPARATE STATEMENT
17111145v.1