Casperson v. The Golden 1 Credit Union, et al.

Filing 21

STIPULATION and ORDER signed by Judge John A. Mendez on 10/25/2013 ORDERING that all dates set in the 15 Scheduling Order are VACATED. It is further ordered that the Parties appear, in person, at a Status Conference on 1/22/2014 at 09:30 AM in Courtroom 6 (JAM) before Judge John A. Mendez. A Joint Status Report shall be filed no later than 14 days prior to the conference. (Zignago, K.)

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Tanya E. Moore, SBN 206683
MOORE LAW FIRM, P.C.
332 North Second Street
San Jose, California 95112
Telephone [phone]
Facsimile [phone]
Email: [e-mail]
Attorneys for Plaintiff
Carl Casperson

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CARL CASPERSON,
Plaintiff,

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vs.
THE GOLDEN 1 CREDIT UNION, a
California Corporation; KORAF
CORPORATION, a California Corporation;
DOUGLAS KNUTSEN; PHYLLIS
KNUTSEN aka PHYLLIS TOKERUD,
Defendants.

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No. 2:13-cv-00481-JAM-KJN
STIPULATION AND [PROPOSED]
ORDER TO VACATE DATES IN
SCHEDULING ORDER AND SET DATE
FOR STATUS CONFERENCE

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STIPULATION AND [PROPOSED] ORDER TO VACATE DATES IN SCHEDULING ORDER AND TO
SET NEW DATE FOR STATUS CONFERENCE
Page 1

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WHEREAS, on October 16, 2013, Tanya E. Moore, counsel of record for plaintiff,

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Carl Casperson (“Plaintiff”), filed a motion to withdraw as Plaintiff’s attorney of record on

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the grounds that her client terminated her services and that she could no longer effectively

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represent him (Dkt. 19);

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WHEREAS, the Court issued a Scheduling Order in this matter on May 15, 2013
(Dkt. 15);

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WHEREAS, after the Scheduling Order issued, defendants and Plaintiff, through

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their counsel, engaged in meaningful settlement negotiations and were cautiously optimistic

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that a settlement would be reached without the expense of extensive discovery, and thus have

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not conducted any discovery in this matter other than a site inspection of the subject

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property;

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WHEREAS, the hearing on Plaintiff’s counsel’s motion to withdraw is set for

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December 11, 2013, which date is after the last date set for expert witness disclosures of

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November 22, 2013, and leaves little time for the parties to engage in the completion of

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discovery prior to the February 28, 2014 discovery cut-off date (which is the last date by

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which all discovery motions must be heard and any orders complied with);

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WHEREAS, if counsel’s motion is granted, at present Plaintiff will be without

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counsel. Plaintiff, or his counsel if he later obtains counsel, will need time to understand the

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case, proceed with discovery and participate in any settlement conference to which the Court

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may refer the parties;

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WHEREAS, Plaintiff’s counsel cannot continue performing substantive work for

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Plaintiff who has terminated her services (such as choosing and disclosing experts), and it

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furthers the interests of justice that new dates be set that are agreeable to Plaintiff (or his new

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counsel) and defendants in light of Plaintiff’s counsel’s pending motion to withdraw.

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NOW, THEREFORE, the parties, by and through their counsel of record, hereby
stipulate as follows:
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All dates set in the Court’s May 15, 2013 Scheduling Order (Dkt. 15) be

vacated; and
STIPULATION AND [PROPOSED] ORDER TO VACATE DATES IN SCHEDULING ORDER AND TO
SET NEW DATE FOR STATUS CONFERENCE
Page 2

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2.

A Status Conference be set for a date after January 15, 2014 at the Court’s

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convenience.

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IT IS SO STIPULATED.

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Dated: October 24, 2013

MOORE LAW FIRM, P.C.

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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff
Carl Casperson

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Dated: Octobr 23, 2013

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/s/ Janlynn R. Fleener
Janlynn R. Fleener
Attorneys for Defendant,
The Golden 1 Credit Union

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DOWNEY BRAND LLP

Dated: October 23 2013

LAW OFFICES OF MATTHEW V. BRADY

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/s/ Matthew V. Brady
Matthew V. Brady
Attorney for Defendants,
Koraf Corporation, Douglas Knutsen,
and Phyllis Knutsen

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ORDER

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The Parties having so stipulated and good cause appearing,

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IT IS HEREBY ORDERED that all dates set in the Scheduling Order dated May 15,

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2013 (Dkt. 15) are hereby VACATED.

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IT IS FURTHER ORDERED that the Parties appear, in person, at a Status Conference

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on January 22, 2014 at 9:30 am, in Courtroom 6, and that a Joint Status Report be filed no later

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than fourteen days prior to the conference.

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IT IS SO ORDERED.
Dated: October 25, 2013

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/s/ John A. Mendez
JOHN A. MENDEZ
United States District Judge

STIPULATION AND [PROPOSED] ORDER TO VACATE DATES IN SCHEDULING ORDER AND TO
SET NEW DATE FOR STATUS CONFERENCE
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