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

Filing 54

STIPULATION and ORDER signed by District Judge John A. Mendez on 5/2/16 ORDERING that the Dispositive Motions deadline is extended to 6/21/2016, and the Dispositive Motions hearing is extended to 7/19/2016 at 1:30 p.m. The Final Pretrial Conference is extended to 8/26/2016 at 11:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. The Jury Trial is extended to 9/26/2016 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Kastilahn, A)

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Rory C. Quintana, SBN 258747
QUINTANA HANAFI
PUNGPRAKEARTI, LLP
201 Spear St., Suite 1100
San Francisco, CA 94102
[phone], Ext. 101 (Tel.)
[phone] (Fax)
[e-mail]

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Attorneys for Plaintiff Virgil Stuckey

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YULI LAW OFFICES
Eliyahu Yuli Kaplunovsky (SBN 299178)
1669-2 Hollenbeck Ave. # 211
Sunnyvale, California 94087
[phone] (Tel)
[e-mail]

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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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VIRGIL STUCKEY, an individual;

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

Plaintiffs,
vs.
U.S.A. TRUCKING, INC., a California
corporation; GURTEJ SINGH, an individual,

STIPULATION TO EXTEND DEADLINE
FOR: DISPOSITIVE MOTIONS,
PRE-TRIALCONFERENCE, AND
TRIAL DATE

Defendants.

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Pursuant to the Parties’ agreement of May 1, 2016, and for the reasons described below, as

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well as an effort to resolve the case through alternative dispute resolution, the Parties’ hereby

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agree to continue the deadlines set forth for Dispositive Motions, the Pre-Trial Conference and

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Trial as described below.

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On April 11, 2016, the Parties stipulated to submit to the Court’s Voluntary Dispute
Resolution Program. Because Defendants’ counsel and Defendant were both out of the country
-1Stuckey v. U.S.A. Trucking, Inc. CAND Case No. 2:14-cv-01091-JAM-DAD
Stipulation to Extend Deadlines and [Proposed] Order For: Dispositive Motions, Pre-Trial Conference and Trial.

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for the next three weeks, the stipulation was not filed until May 1, 2016.

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Plaintiff intends to file a Motion for Summary Adjudication, however both Parties agree

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that a pending summary judgment or adjudication motion would be a detriment to resolution

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discussions. Given the stipulation for to submit to the Voluntary Dispute Resolution Program,

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and the foregoing facts, the Parties have agreed to continue the deadlines set forth for Dispositive

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Motions, the Pre-Trial Conference and Trial as follows: (1) Dispositive Motions Deadline,

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currently set for May 3, 2016 will be extended to June 21, 2016, and the Dispositive Motions

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hearings, currently set for May 31, 2016 will be extended to July 19, 2016 at 1:30 p.m.; (2) the

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Pre-Trial Conference, currently set for July 1, 2016 at 11:00 a.m. will be extended to August 26,

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2016 at 11:00 a.m.; and JURY TRIAL currently set for August 1, 2016 at 9:00 a.m. will be

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extend to September 26, 2016 at 9:00 a.m. in Courtroom 6 before Judge John A. Mendez.

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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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WHERAS, Plaintiff and Defendants agreed to the above scheduling changes before filing
Motions for Summary Judgment or Adjudication on May 1, 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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IT IS SO STIPULATED

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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: Dispositive Motions, Pre-Trial Conference and Trial.

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Dated: May 1, 2016

QUINTANA HANAFI
PUNGPRAKEARTI, LLP

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By: __s/s Rory C. Quintana___________
Rory C. Quintana
Attorney for Plaintiff Virgil Stuckey

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Dated: May 1, 2016

YULI LAW OFFICES

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By: __/s/Eliyahu Yuli Kaplunovsky__
Eliyahu 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 by its signatory

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By: __s/s Rory C. Quintana___________
Rory C. Quintana

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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: 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:

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1. The proposed deadlines as modified by the Court above, shall be granted.

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IT IS SO ORDERED.

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DATED: May 2, 2016

/s/ John A. Mendez________________________
UNITED STATES DISTRICT COURT JUDGE

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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: Dispositive Motions, Pre-Trial Conference and Trial.