Owens v. Walgreen Co.

Filing 35

ORDER signed by Senior Judge William B. Shubb on 2/5/2013 SETTING a Motion Hearing as to 34 Motion to Continue Trial; Unopposed Motion to be Relieved as Counsel for 2/11/2013 at 02:00 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb; ORDERING that both motions be filed immediately; ORDERING counsel for Plaintiff, Shaun Owens, to assure Plaintiff's appearance at the Motion Hearing set for 2/11/2013. (Michel, G)

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LAWRANCE A. BOHM, (SBN 208716)
BOHM LAW GROUP
4600 Northgate Boulevard, Suite 210
Sacramento, CA 95834
Telephone: [phone]
Facsimile: [phone]

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ERIKA M. GASPAR, (SBN 238117)
LAW OFFICE OF ERIKA M. GASPAR
2121 Natomas Crossing Drive, Suite 200-399
Sacramento, CA 95834
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
SHAUN OWENS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No. 2:12−CV−00419−WBS−JFM

SHAUN OWENS,
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Plaintiff,
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v.
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WALGREEN CO.; and DOES 1-100, inclusive,
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STIPULATION FOR ORDER
SHORTENING TIME FOR HEARING
OF PLAINTIFF’S UNOPPOSED
MOTION TO CONTINUE THE DATE
OF TRIAL AND OF UNOPPOSED
MOTION OF PLAINTIFF’S
ATTORNEYS TO BE RELIEVED AS
COUNSEL; (PROPOSED) ORDER

Defendant.

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Judge: Hon. William B. Shubb

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Plaintiff, SHAUN OWENS, by and through his attorneys of record, Lawrance A. Bohm

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and Erika M. Gaspar and Defendant, WALGREEN CO., by and through their attorney of record

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Rex Darrell Berry stipulate to an Order Shortening Time pursuant to Federal Rules of Civil

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Procedure Rule 6 and Local Rule 144(e) for a hearing of Plaintiff’s Motion to Continue the Date

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SHAUN OWENS v. WALGREEN CO.
Case No. 2:12−CV−00419−WBS−JFM

Stipulation For Order Shortening Time For Hearing Of
Plaintiff’s Motion To Continue The Date of Trial and of
Unopposed Motion of Plaintiff’s Attorneys to be
Relieved as Counsel; (Proposed) Order

Lawrance A. Bohm, Esq.
Erika M. Gaspar, Esq.

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of Trial and of the Unopposed Motion of Plaintiff’s Attorneys to be Relieved as Counsel,

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submitted herewith, to be set for February 11, 2013 at 2:00 p.m.

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I. EXISTENCE OF GOOD CAUSE

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1.

Good cause exists in Plaintiff is seeking other counsel for representation in

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this matter.
2.

Good cause exists in that Plaintiff will be prejudiced if the motions

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submitted herewith are not heard on shortened time. Defendant will not be prejudiced if

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the motions are heard on shortened time as it does not oppose the motions and does not

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intend to file an opposition.
3.

Good cause exists in that before the referenced matters can be heard and

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ruled on by this Court pursuant to Local Rule 230 and Federal Rules of Civil Procedures
78, two crucial trial-related deadlines will have passed:

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the current date for disclosure of experts and reports per Rule 26(a)(2)

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is February 15, 2013. (Doc. 33);

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the current deadline by which responses are due to the currently

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outstanding written discovery, and the deadline for completion of the

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pending previously noted depositions is February 25, 2013 (Doc. 33).
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4.

Good cause exists in that counsel for the parties believe the interests of

justice and efficiency would be served by an Order granting the request to shortening time.

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Dated: February 5, 2013

By:

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/s/Erika M. Gaspar
LAWRANCE A. BOHM, ESQ.
ERIKA M. GASPAR, ESQ.
Attorneys for Plaintiff
SHUAN OWENS

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SHAUN OWENS v. WALGREEN CO.
Case No. 2:12−CV−00419−WBS−JFM

Stipulation For Order Shortening Time For Hearing Of
Plaintiff’s Motion To Continue The Date of Trial and of
Unopposed Motion of Plaintiff’s Attorneys to be
Relieved as Counsel; (Proposed) Order

Lawrance A. Bohm, Esq.
Erika M. Gaspar, Esq.

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Dated: February 1, 2013

By:

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/s/Rex Darrell Berry
REX DARRELL BERRY, ESQ.
BERRY & BLOCK LLP
Attorneys for Defendant
WALGREEN, CO.

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ORDER
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GOOD CAUSE APPEARING, the Court sets the matters for hearing as follows:
Motion:

Hearing Date & Time:

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Plaintiff’s Unopposed Motion to Continue the Date of

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Trial and to Modify the Status (Pretrial Scheduling) Order

February 11, 2013 at 2:00 p.m.

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Unopposed Motion of Plaintiff’s Attorneys to be Relieved

February 11, 2013 at 2:00 p.m.

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As Counsel.

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Both motions shall be filed immediately. Counsel for plaintiff, Shaun Owens, is

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ordered to assure the plaintiff’s appearance at the hearing on the motion to withdraw, set

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for February 11, 2013 at 2:00 p.m.

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IT IS SO ORDERED:
Date:

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February 5, 2013

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SHAUN OWENS v. WALGREEN CO.
Case No. 2:12−CV−00419−WBS−JFM

Stipulation For Order Shortening Time For Hearing Of
Plaintiff’s Motion To Continue The Date of Trial and of
Unopposed Motion of Plaintiff’s Attorneys to be
Relieved as Counsel; (Proposed) Order

Lawrance A. Bohm, Esq.
Erika M. Gaspar, Esq.