Stuckey v. U.S.A. Trucking Inc. et al

Filing 26

STIPULATION and ORDER signed by Judge John A. Mendez on 4/17/15 ORDERING that discovery is due by 8/10/2015, dispositive motions due by 8/19/2015, the hearing on dispositive motions shall be noticed for 9/16/2015 at 9:30 a.m., the Pretrial Con ference is SET for 12/4/2015 at 10:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez, the joint pretrial statement due by 11/27/2015, and the Jury Trial is SET for 1/25/2016 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Kastilahn, A)

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Rory C. Quintana (SBN 258747)
QUINTANA HANAFI
PUNGPRAKEARTI, LLP
201 Spear Street, Suite 1100
San Francisco, CA 94105
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff Virgil Stuckey
YULI LAW OFFICES
Yuli Kaplunovsky (SBN 299178)
1669-2 Hollenbeck Ave. #211
Sunnyvale, California 94087
Telephone: [phone]
E-Mail: [e-mail]
Attorneys for Defendants USA Trucking, Inc.
and Gurtej Singh

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CASE NO. 2:14-cv-01091-JAM-DAD

VIRGIL STUCKEY, an individual;

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STIPULATION TO EXTEND DEADLINES
AND ORDER FOR: DISCOVERY CUT-OFF,
DISPOSITIVE MOTIONS, PRE-TRIAL
CONFERENCE, AND TRIAL DATE

Plaintiffs,

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vs.

(AS MODIFIED BY THE COURT)

U.S.A. TRUCKING, INC., a California
corporation; GURTEJ SINGH, an individual,
and DOES 1 through 50, inclusive,

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Case No. 2:14-cv-01091

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STIPULATION TO EXTEND DEADLINES AND
[PROPOSED] ORDER FOR: DISCOVERY CUT-OFF, , AND
DISPOSITIVE MOTIONS, PRE-TRIAL CONFERENCE AND
TRIAL

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Pursuant to the Parties’ agreement of April 14, 2015, and in an effort to continue good

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faith efforts toward informal resolution, the parties hereby agree to continue the deadlines set

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forth for Discovery, Motions, the Pre-Trial Conference and Trial as follows: (1) the Discovery

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Deadline, currently set for April 10, 2015, will be extended to August 10, 2015; (2) Dispositive

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Motions Deadline, currently set for May 20, 2015, will be extended to August 19, 2015; Hearing

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on dispositive motions shall be noticed for September 16, 2015 at 9:30 a.m. (3) the Pre-Trial
Conference, currently set for July 29, 2015 at 4:00 p.m., will be extended to December 4, 2015,
at 10:00 a.m. The joint pretrial statement shall be filed no later than November 27, 2015; and (4)
the Jury Trial, currently set for September 21, 2015, will be extended to January 25, 2016 at 9:00
a.m..
The parties respectfully request the Court enter an order that current deadlines listed
above be extended as agreed to by the parties.
WHEREAS, Plaintiff and Defendants agreed to the above scheduling changes during a
telephone conference on April 14, 2015;

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THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff and Defendants

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through their designated counsel that the above scheduling changes be granted and entered by the

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Court.

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IT IS SO STIPULATED.

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Dated: April 15, 2015

QUINTANA HANAFI PUNGPRAKEARTI, LLP

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By:___s/Rory C. Quintana_______________
Rory C. Quintana
Attorney for Plaintiff Henry M. Burgoyne, III

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Case No. 2:14-cv-01091

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STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: DISCOVERY CUT-OFF, DISPOSITIVE
MOTIONS, PRE TRIAL CONFERENCE AND TRIAL

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Dated: April 15, 2015

YULI LAW OFFICES

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By:___s/Yuli Kaplunovsky_______________
Yuli Kaplunovsky
Attorney for Defendants Gurtej Singh and
U.S.A. Trucking, Inc.

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Filer’s Attestation: I attest under penalty of perjury that concurrence in the filing of the
document has been obtained from its signatory.

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Respectfully submitted,

Dated: April 15, 2015

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By:___s/Rory C. Quintana_______________

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Rory C. Quintana

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Case No. 2:14-cv-01091

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STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: DISCOVERY CUT-OFF, DISPOSITIVE
MOTIONS, PRE TRIAL CONFERENCE AND TRIAL

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The Court having considered the stipulation of the parties, and good cause appearing
therefore, orders as follows:
1. The proposed deadlines as described above shall be granted, except as
otherwise modified by the Court.

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IT IS SO ORDERED.

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Dated: 4/17/2015

/s/ John A. Mendez
UNITED STATES DISTRICT COURT JUDGE
EASTERN DISTRICT OF CALIFORNIA

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Case No. 2:14-cv-01091

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STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: DISCOVERY CUT-OFF, DISPOSITIVE
MOTIONS, PRE TRIAL CONFERENCE AND TRIAL

CERTIFICATE OF SERVICE

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I, Rory C. Quintana, hereby certify that on April 17, 2015, I authorized and served by

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electronic means on the parties listed below, as follows:

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YULI LAW OFFICES
Yuli Kaplunovsky
1669-2 Hollenbeck Ave. #211
Sunnyvale, California 94087
Telephone: [phone]
E-Mail: [e-mail]

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I certify under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed on April 17, 2015.

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By:___s/Rory C. Quintana_______________
Rory C. Quintana
Attorney for Plaintiff Virgil Stuckey

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Case No. 2:14-cv-01091

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STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: DISCOVERY CUT-OFF, DISPOSITIVE
MOTIONS, PRE TRIAL CONFERENCE AND TRIAL