Price v. Martin et al

Filing 23

STIPULATION and ORDER signed by Judge John A. Mendez on 1/29/15 ORDERING that the Status (Pre-trial Scheduling) Order is modified as follows: Discovery cutoff: 4/10/15; Dispositive motion filing: 5/20/15; Dispositive motion hearing: 6/17/15 @ 9 :30 AM; Joint pre-trial statement due: 7/24/15; Pretrial Conference SET for 7/31/2015 at 10:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez; Jury Trial SET for 9/28/2015 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Kastilahn, A)

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DELTA LAW GROUP
A PROFESSIONAL LAW CORPORATION
JIM G. PRICE, ESQ., SBN 119324
6569 BRENTWOOD BOULEVARD
P.O. BOX 1417
BRENTWOOD, CA 94513
TELEPHONE: [phone]
FACSIMILE: 925-516-4058
EMAIL: [e-mail]
Attorneys for Plaintiff
BARBARA M. PRICE

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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BARBARA M. PRICE,
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Plaintiff,
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v.
JAMES MARTIN, CHRONIC HEALTH
SOLUTIONS, DENT-A-MED dba HC
PROCESSING CENTER and DOES 1
through 20, inclusive,

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Defendants.
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) Case No. 2:14-cv-00283-JAM-EFB
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) STIPULATION FOR EXTENSION OF
) DISCOVERY DEADLINES; ORDER
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STIPULATION
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Plaintiff BARBARA M. PRICE, and Defendant DENT A MED, INC.
dba HC PROCESSING CENTER, hereby stipulate that the Court's

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Status (Pre-trial Scheduling) Order dated July 21, 2014, a copy

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of which is attached hereto as Exhibit "A", be modified as

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follows:

STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES; [PROPOSED] ORDER

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Discovery cutoff:

4/10/15;

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Dispositive motion filing:

5/20/15;

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3.

Dispositive motion hearing:

6/17/15 @ 9:30 AM;

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Joint pre-trial statement due:

7/24/15;

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Pretrial conference:

7/31/15 @ 10:00 AM;

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Jury trial:

9/28/15 @ 9:00 AM.

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There is good cause for the proposed modification of the
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Status (Pre-trial Scheduling) Order.

The parties have engaged

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in extensive written discovery but before taking expensive

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depositions, which would entail cross-country travel, the

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parties want to explore settlement negotiations.

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discovery deadline would permit the parties to do so.

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Extending the

There have not been any previous time modifications related
to discovery in this case.
For the foregoing reasons, and good cause appearing, the
parties request that the Court modify the Status (Pre-trial
Scheduling) Order as set forth herein.
IT IS SO STIPULATED.

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DATED: January 27, 2015

DELTA LAW GROUP

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/s/ Jim G. Price
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BY:_______________________________
JIM G. PRICE*
Attorneys for Plaintiff
BARBARA M. PRICE

STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES; [PROPOSED] ORDER

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DATED: January 27, 2015

SUPPA, TRUCCHI & HENEIN, LLP

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/s/ Samy S. Henein

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BY:_______________________________
SAMY S. HENEIN
Attorneys for Defendant
DENT A MED, INC. dba
HC PROCESSING CENTER

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ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED:

January 29, 2015

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/s/ JOHN A. MENDEZ
______________________________________
JOHN A. MENDEZ
United States District Court Judge

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*I, Jim G. Price, am the ECF user whose identification and
password are being used to file this Stipulation for Discovery
Deadlines. I hereby attest that Samy S. Henein has concurred in
this filing.
/s/ Jim G. Price

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STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES; [PROPOSED] ORDER

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