Andrews v. Pride Industries et al

Filing 88

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 6/28/16 ORDERING that the filing and service deadline for the Joint Pre-Trial Conference Statement is CONTINUED to 7/15/2016. The Final Pretrial Conference is CONTINUED to 7/29/2016 at 10:00 AM in Courtroom 3 (KJM) before District Judge Kimberly J. Mueller. (Kastilahn, A)

1 GILBERT, KELLY, CROWLEY & JENNETT LLP
DAVID M. DANIELS, BAR NO. 170315

2 JENNIFER CALDERON SCHMULDT, BAR NO. 234448
1013 Galleria Boulevard, Suite 205

3 Roseville, California 95678-1363

[phone]; FAX: [phone]

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5 MAILING ADDRESS:

550 South Hope Street, 22nd Floor

6 Los Angeles, California 90071-2627

[phone]; FAX [phone]

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Attorneys for Defendants

8 PRIDE INDUSTRIES and JEAN ZURBUCHEN
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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12 NAPOLEON ANDREWS,
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Case No. 2014-CV-02154-KJM-AC

Plaintiff,

Assigned to the Hon. Kimberly J. Mueller

v.

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PRIDE INDUSTRIES, JEAN ZURBUCHEN, as
15 individuals and Does 1-10, inclusive,

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Defendants.

JOINT STIPULATION AND ORDER
CONTINUING FILING AND SERVICE
DEADLINE FOR JOINT PRE-TRIAL
CONFERENCE STATEMENT AND
FINAL PRE-TRIAL CONFERENCE

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Plaintiff NAPOLEON ANDREWS (“Plaintiff”), and Defendants PRIDE INDUSTRIES and

19 JEAN ZURBUCHEN (collectively referred to as “PRIDE”), constituting all the parties appearing
20 in this action, through the undersigned counsel of record, hereby stipulate to continue the deadline
21 for filing and service of the Joint Pre-Trial Conference Statement and all supporting materials
22 from June 30, 2016, to July 8, 2016, and further stipulate to continue the Final Pre-Trial
23 Conference from Thursday, July 21, 2016, to Friday, July 22, 2016.
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Reasons for Continuance.

Due to previous modifications of the Court’s Status

25 (Scheduling and Pre-Trial Order), PRIDE’S Motion for Summary Judgment was not heard until
26 May 18, 2016. To date, the parties have not received the Court’s Order on this substantive and
27 dispositive motion, which will no doubt affect the proposed exhibits, witnesses, motions in limine,
28 and other trial matters that are to be submitted with the Joint Pre-Trial Conference Statement. In
Gilbert, Kelly
Crowley & Jennett LLP
Attorneys at Law

JOINT STIPULATION AND ORDER CONTINUING FILING AND SERVICE DEADLIE FOR JOINT PRETRIAL CONFERENCE STATEMENT AND FINAL PRE-TRIAL CONFERENCE
4041687.1 07181-00002 DMD

1 order to allow time for the Court to rule upon said motion, and for the parties to prepare
2 accordingly for the compilation of the Joint Pre-Trial Statement, and the Final Pre-Trial
3 Conference, the dates should be continued to a reasonable and available date for the parties, and for
4 the Court’s calendar. The parties wish to have the current trial date of August 29, 2016, remain
5 undisturbed. The continuance of the above-related dates would still provide more than a month of
6 time between the Final Pre-Trial Conference and the Trial date of August 29, 2016, to allow the
7 current trial to remain even with the grant of this proposed continuance. The parties are informed
8 that the Court is currently available on the dates to which they Stipulate.
Now, therefore, IT IS STIPULATED by and between all parties to this action as follows:

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1. That the filing and service deadline for the Joint Pre-Trial Conference Statement,

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currently set for June 30, 2016, be continued to July 8, 2016; and

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2. That the Final Pre-Trial Conference, currently set for Thursday, July 21, 2016, be

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continued to Friday, July 22, 2016.

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SO STIPULATED.

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ROSA LAW GROUP

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17 Dated:

/s/Andrea Rosa
ANDREA ROSA
Attorney for Plaintiff, NAPOLEON
ANDREWS

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GILBERT KELLY CROWLEY & JENNETT

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23 Dated: June 24, 2016

/s/ Jennifer C. Schmuldt
DAVID M. DANIELS
JENNIFER C. SCHMULDT
Attorneys for Defendants, PRIDE
INDUSTRIES, AND JEAN ZURBUCHEN

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/././
ORDER

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Gilbert, Kelly
Crowley & Jennett LLP
Attorneys at Law

-2JOINT STIPULATION AND ORDER CONTINUING FILING AND SERVICE DEADLINE FOR JOINT PRETRIAL CONFERENCE STATEMENT AND FINAL PRE-TRIAL CONFERENCE
4041687.1 07181-00002

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Based on the Joint Stipulation of the parties, the court’s schedule and good cause appearing

2 therefor, IT IS ORDERED that the filing and service deadline for the Joint Pre-Trial Conference
3 Statement, currently set for June 30, 2016, be and hereby is continued to July 15, 2016. IT IS
4 FURTHER ORDERED that the Final Pre-Trial Conference currently set for Thursday, July 21,
5 2016 at 3:30 p.m., be and hereby is continued to Friday, July 29, 2016 at 10:00 a.m.
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IT IS SO ORDERED.

7 DATED: June 28, 2016
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9

UNITED STATES DISTRICT JUDGE

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Gilbert, Kelly
Crowley & Jennett LLP
Attorneys at Law

-3JOINT STIPULATION AND ORDER CONTINUING FILING AND SERVICE DEADLINE FOR JOINT PRETRIAL CONFERENCE STATEMENT AND FINAL PRE-TRIAL CONFERENCE
4041687.1 07181-00002