Kitchen v. Lodi Unified School District

Filing 30

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 1/8/2015 GRANTING all parties an EXTENSION to serve initial disclosures to 3/13/2015. (Zignago, K.)

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ALESA SCHACHTER, ESQ. (SBN 102542)
JASON M. SHERMAN, ESQ. (SBN 245190)
JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation
California Plaza
2180 Harvard Street, Suite 560
Sacramento, CA 95815
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for DEFENDANTS:
LODI UNIFIED SCHOOL DISTRICT,
CATHERINE NICHOLS-WASHER, and
NEIL YOUNG

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TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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JEANNE KITCHEN,

)
)
)
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Plaintiff,
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v.
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LODI UNIFIED SCHOOL DISTRICT;
CATHERINE NICHOLS-WASHER, in her )
official capacity as Superintendent of the Lodi )
Unified School District, NEIL YOUNG in his )
official capacity as Director of Personnel of )
)
the Lodi Unified School District,
)
)
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Defendants.
)

CASE NO. 2:14-cv-01436-WBS-EFB
STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION TO ALL
PARTIES TO SERVE RULE 26(a)(1)
INITIAL DISCLOSURES

Complaint Filed:
Trial Date:

June 16, 2014
None Set

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Pursuant to Local Rule 144(a), the parties agree and stipulate that an extension should be

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granted to all parties to serve initial disclosures required by Federal Rule of Civil Procedure

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26(a)(1):

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In the Scheduling Order issued by the Court on November 24, 2014, the Court

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ordered the parties to serve initial disclosures required by Federal Rule of Civil

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Procedure 26(a)(1) by no later than January 30, 2015;
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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION TO ALL PARTIES TO SERVE RULE
26(a)(1) INITIAL DISCLOSURES

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Counsel for Plaintiff and Defendants have met and conferred and agreed that both
sides would like additional time to prepare initial disclosures;

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Defendants have filed a motion to dismiss Plaintiff’s First Amended Complaint,

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which is scheduled for a hearing on February 23, 2015, and the parties agree that an

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extension will not substantively delay the case

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-

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The parties have agreed to an extension of six weeks (42 days) to serve initial
disclosures, on March 13, 2015.

initial disclosures required by Federal Rule of Civil Procedure 26(a)(1) to March 13, 2015.

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TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

The parties therefore agree and stipulate that all parties should be granted an extension to serve

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JOHNSON SCHACHTER & LEWIS

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The parties respectfully request an order from the Court allowing all parties an extension
to serve initial disclosures required by Federal Rule of Civil Procedure 26(a)(1) to March 13,
2015.

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Dated: January 8, 2015

JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation

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By: /s/ Alesa Schachter____________________
ALESA SCHACHTER
JASON M. SHERMAN
Attorneys for Defendant LODI UNIFIED
SCHOOL DISTRICT

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Dated: January 8, 2015

THE LEGAL AID SOCIETY - EMPLOYMENT
LAW CENTER
By: /s/ Jinny Kim (authorized on January 8, 2015)
JINNY KIM
Attorneys for Plaintiff, JEANNE KITCHEN

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: January 8, 2015

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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION TO ALL PARTIES TO SERVE RULE
26(a)(1) INITIAL DISCLOSURES