Hill v. The Sygma Network, Inc.

Filing 14

STIPULATION AND ORDER signed by Chief Judge Morrison C. England, Jr. on 9/3/2014 ORDERING 13 Discovery due by 11/14/2014; Disclosure of Expert Witnesses due by 1/15/2015; and Dispositive Motions filed by 4/2/2015. (Reader, L)

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LAW OFFICE OF JEFFREY D. FULTON
Jeffrey D. Fulton (Bar No. 206466)
Natalya Grunwald (Bar No. 265084)
2150 River Plaza Drive, Suite 260
Sacramento, California 95833
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff
ERIC HILL
Julius M. Turman, Esq. (SBN. No. 226126)
Philip Smith, Esq. (SBN No. 232462)
REED SMITH LLP
101 Second Street
Suite 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
[e-mail]
Attorneys for Defendant
THE SYGMA NETWORK, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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Case No. 2:13-cv-02638-MCE-EFB

ERIC HILL
Plaintiff,
v.
THE SYGMA NETWORK, INC. and DOES 1
through 100, INCLUSIVE,

STIPULATION TO CONTINUE
DISCOVERY AND HEARING ON
DISPOSITIVE MOTIONS DEADLINE AND
ORDER GRANTING THE REQUEST TO
CONTINUE DISCOVERY AND HEARING
ON DISPOSITIVE MOTIONS DEADLINE

Defendants.

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CASE NO. 2:13-CV-02638-MCE-EFB
STIPULATION TO CONTINUE DISCOVERY AND HEARING ON DISPOSITIVE MOTIONS DEADLINE

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Plaintiff ERIC HILL (“Plaintiff” or “Hill”) and Defendant THE SYGMA NETWORK,
INC. (“Defendant” or “Sygma”) by and through their counsel, hereby stipulate as follows:

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WHEREAS, Plaintiff filed the Complaint on October 24, 2013.

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WHEREAS, Defendant removed this matter to this Court on December 20, 3013.

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WHEREAS, per this Court’s Pretrial Scheduling Order of March 18, 2014,

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discovery shall be completed by September 19, 2014.
WHEREAS, the parties timely exchanged initial disclosures and engaged in written
discovery.

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WHEREAS, Defendant has previously noticed Plaintiff’s deposition to be held on

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July 18 and August 12, 2014, but has been unable to commence Plaintiff’s deposition due to

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defense counsel’s unanticipated scheduling conflicts.

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WHEREAS, the parties have agreed to schedule Plaintiff’s deposition for August
28, 2014.

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WHEREAS, Defendant intends to serve supplemental disclosures, pursuant to

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Federal Rule of Civil Procedure 26(e), based upon its identification of additional information

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subject to disclosure which may not be known to Plaintiff.

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WHEREAS, due to scheduling conflicts and trial calendar, Plaintiff’s counsel is

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unable to complete discovery, specifically depositions of key witnesses by discovery cut-off

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date of September 19, 2014.

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WHEREAS, per this Court’s Pretrial Scheduling Order, the final pretrial conference
is scheduled for May 28, 2015.

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WHEREAS, per this Court’s Pretrial Scheduling Order, trial is set for July 20, 2015.

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WHEREAS, the parties desire to extend the fact discovery deadline from September

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19 to November 14, 2014.
WHEREAS, the parties desire to extend the deadline to disclose expert witnesses
from November 20 until January 15, 2014.
WHEREAS, the parties desire to extend the deadline to hear dispositive motions
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CASE NO. 2:13-CV-02638-MCE-EFB

STIPULATION TO CONTINUE DISCOVERY AND HEARING ON DISPOSITIVE MOTIONS DEADLINE

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from March 19 to April 2, 2015.

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WHEREAS, the parties’ desired extension for discovery and hearing dispositive

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motions deadlines will not affect the Court’s schedule for the final pretrial conference and

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trial.
THEREFORE, although Plaintiff desired a slightly greater extension, Plaintiff and

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Defendant currently stipulate to extend the fact discovery deadline to November 14, 2014.

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THEREFORE, Plaintiff and Defendant stipulate to extend the expert witness

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disclosure deadline to January 15, 2015, with an equivalent extension of all attendant expert

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discovery deadlines arising thereafter.
THEREFORE, Plaintiff and Defendant stipulate to extend the deadline to hear

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dispositive motions to April 2, 2015.

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IT IS SO STIPULATED.

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DATED: August 26, 2014

LAW OFFICE OF JEFFREY D. FULTON

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By: /s/ Jeffrey D. Fulton
Jeffrey D. Fulton
Natalya Grunwald
Attorneys for Plaintiff,
ERIC HILL

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CASE NO. 2:13-CV-02638-MCE-EFB

STIPULATION TO CONTINUE DISCOVERY AND HEARING ON DISPOSITIVE MOTIONS DEADLINE

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DATED: August 26, 2014

REED SMITH LLP

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By: /s/ L. Julius M. Turman
L. Julius M. Turman
Philip J. Smith
Attorneys for Defendant,
THE SYGMA NETWORK, INC.

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ORDER

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IT IS SO ORDERED.
Dated: September 3, 2014

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CASE NO. 2:13-CV-02638-MCE-EFB

STIPULATION TO CONTINUE DISCOVERY AND HEARING ON DISPOSITIVE MOTIONS DEADLINE