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

Filing 50

STIPULATION and ORDER for extension of deadlines and hearings signed by Judge John A. Mendez on 2/23/16. The Discovery is EXTENDED to 4/11/2016. Dispositive Motions are now due on 5/3/2016. The Dispositive Motion Hearings currently set for notice on 4/5/2016 will now be set for 5/31/2016 at 1:30 PM. Joint Pretrial Statements are now due on 6/24/2016. Final Pretrial Conference is CONTINUED to 7/1/2016 at 11:00 AM, and Jury Trial is CONTINUED to 8/1/2016 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Kastilahn, A)

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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

Rory C. Quintana, SBN 258747
QUINTANA HANAFI
PUNGPRAKEARTI, LLP
201 Spear St., Suite 1100
San Francisco, CA 94102
[phone] (Tel.)
[phone] (Fax)
[e-mail]
Attorneys for Plaintiff Virgil Stuckey

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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VIRGIL STUCKEY, an individual;

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

Plaintiffs,

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

vs.

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

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-1Stuckey v. U.S.A. Trucking, Inc. CAND Case No. 2:14-cv-01091-JAM-DAD
Stipulation to Extend Deadlines and [Proposed] Order For: Discovery Cut-Off, Dispositive Motions, Pre-Trial
Conference and Trial.

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Pursuant to the Parties’ agreement of February 22, 2016, and for the reasons described

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below, as well as an effort to continue good faith and ongoing efforts toward informal resolution,

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the parties’ hereby agree to continue the deadlines set forth for Discovery, Motions, the Pre-Trial

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Conference and Trial as described below.

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Following the Court’s October 20, 2015 order to extend time, the Parties met and

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conferred regarding Defendants’ discovery responses. The Plaintiff’s counsel conducted over

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five depositions and the Defendant’s counsel conducted deposition of the Plaintiff as well. Both

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parties agreed that more documentary evidence would be needed.

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Based on these facts and ongoing discovery issues related in part to the fact that

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Defendant’s mother died and he was not available for deposition for few months, the Parties

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have agreed to continue the deadlines set forth for Discovery, Motions, the Pre-Trial Conference

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and Trial as follows:

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(1) Discovery Deadline, currently set for 2/22/2016, will be extended to 4/11/2016;

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(2) Dispositive Motions Deadline, currently set for 3/8/2016 will be extended to 5/3/2016

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(3) Dispositive Motion hearings, currently set for notice on 4/5/2016 at 9:30 a.m. will be set for

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5/31/2016 at 1:30 P.M. ;

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(4) Joint pretrial statements, currently due by 5/6/2016, due on 6/24/2016;

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(5) Final Pre-Trial Conference, currently set for 5/13/2016 at 11:00 a.m. will be extended to

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7/1/2016 at 11:00 a.m. ,

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(6) Jury Trial, currently set for 6/13/2016, at 9:00 a.m. will be extended to 8/1/2016 at 9:00 a.m.

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The parties respectfully request the Court enter an order that current deadlines listed
above be extended as agreed to by the parties.

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WHEREAS, Plaintiff and Defendants agreed to the above scheduling changes 2/22/2016;

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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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-2Stuckey v. U.S.A. Trucking, Inc. CAND Case No. 2:14-cv-01091-JAM-DAD
Stipulation to Extend Deadlines and [Proposed] Order For: Discovery Cut-Off, Dispositive Motions, Pre-Trial
Conference and Trial.

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IT IS SO STIPULATED.

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Dated: 2/22/2016

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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Dated: 2/22/2016

QUINTANA HANAFI
PUNGPRAKEARTI, LLP

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By: __/s/Rory C. Quintana_____________
Rory C. Quintana
Attorney for Plaintiff Virgil Stuckey

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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.
By: __/s/Yuli Kaplunovsky_____________
Yuli Kaplunovsky

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Stuckey v. U.S.A. Trucking, Inc. CAND Case No. 2:14-cv-01091-JAM-DAD
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 as modified by the Court shall be
granted.
IT IS SO ORDERED

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Dated: 2/23/2016

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

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-4Stuckey v. U.S.A. Trucking, Inc. CAND Case No. 2:14-cv-01091-JAM-DAD
Stipulation to Extend Deadlines and [Proposed] Order For: Discovery Cut-Off, Dispositive Motions, Pre-Trial
Conference and Trial.