Samuels v. Owens-Brockway Glass Container Inc.

Filing 13

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 10/22/13: The deadline to file a motion to amend the pleadings under FRCP 15(a) is extended from its current date of December 2, 2013 to January 31, 2014. (Kaminski, H)

1 SCHIFF HARDIN LLP
Stephen M. Hankins (CSB #154886)
2 [e-mail]
Sarah D. Youngblood (CSB #244304)
3
[e-mail]
4 One Market Plaza, Spear Street Tower
Thirty-Second Floor
5 San Francisco, CA 94015
Telephone: [phone]
6 Facsimile: 415-901-8701
7

Attorneys for Defendant
8 OWENS-BROCKWAY GLASS CONTAINER INC.
9 SANDRA J. COHEN, CA SB#. 85045
300 South First Street, Suite 320
10 San Jose CA 95113
408-975-0545
11
e-mail:[e-mail]
12
Attorney for Plaintiff ELIZABETH SAMUELS
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION
15
16
17

ELIZABETH SAMUELS,
Plaintiff,

18

vs.
19 OWENS-BROCKWAY GLASS
CONTAINER, INC. and DOES I through V,
20
Defendants.
21
22

CASE NO. 2:13-CV-00713-GEB-DAD
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE TO
FILE FRCP 15(a) MOTION TO AMEND
PLEADINGS
Judge: Honorable Garland E. Burrell

The parties, by and through their attorneys of record have met and conferred and agreed to

23 the following stipulation:
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(1)

On July 8, 2013, the Court entered its Pretrial Scheduling Order setting the

25 discovery and trial schedule in this matter. See Docket No. 11.
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(2)

Pursuant to this order, the parties’ last day to “file a motion in which leave is

27 sought under Federal Rule of Civil Procedure 15(a) to amend their pleadings in response to
28 information obtained during discovery” is December 2, 2013. Id. Also pursuant to this order, the
2:13-CV-00713-GEG-DAD
1
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE FRCP 15(a) MOTION TO
AMEND PLEADINGS

1 close of fact discovery is not until October 14, 2014 and trial is scheduled for May 19, 2015. Id.
(3)

2

The parties have each served written discovery on each other and are in the process

3 of preparing their respective responses. The parties have yet to conduct any depositions in this
4 case.
5

(4)

Given the current status of discovery in this case, the parties have met and

6 conferred and agreed that an extension of the parties’ deadline to file a motion to amend the
7 pleadings under FRCP 15(a) would be in the best interest of each party.
8

(5)

The parties have not previously requested nor received an extension of this

9 deadline.
10

Therefore, the parties have agreed to and propose a brief extension of the current deadline

11 to file a motion to amend the pleadings under FRCP 15(a) from its current date of December 2,
12 2013 to January 31, 2014.
13

IT IS SO STIPULATED.

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15 Dated: October 17, 2013

SANDRA J. COHEN

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18

By: /s/ Sandra J. Cohen (approved 10/17/13)
Sandra J. Cohen
Attorneys for Plaintiff
ELIZABETH SAMUELS

19 Dated: October 17, 2013

SCHIFF HARDIN LLP

17

20
By: /s/ Sarah D. Youngblood
Sarah D. Youngblood
Attorneys for Defendant
OWENS-BROCKWAY GLASS
CONTAINER INC.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: October 22, 2013

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2:13-CV-00713-GEG-DAD
2
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE FRCP 15(a) MOTION TO
AMEND PLEADINGS