Schmidt et al v. Shasta County Marshal's Office et al

Filing 16

AMENDED JOINT STIPULATION AND ORDER TO CONTINUE PRETRIAL DEADLINES signed by Chief Judge Morrison C. England, Jr on 12/1/15 ORDERING Disclosure of Expert Witnesses due by 6/23/16; Discovery deadline by 4/22/16; Dispositive Motions due by 10/20/16 ; Non-Dispositive Motions due by 1/19/17; Joint Final Pretrial Conference Statements due by 1/19/17; Final Pretrial Conference set for 2/9/17 at 02:00; Jury Trial set for 4/3/17 at 09:00 AM in Courtroom 7 (MCE) before Chief Judge Morrison C. England Jr; Settlement conference statements due 5/12/16; Settlement Conference set for 5/19/16 at 09:00 AM in Courtroom 26 (AC) before Magistrate Judge Allison Claire. (Becknal, R)

1
2
3
4
5
6
7
8

TIMOTHY G. YEUNG (SBN 186170)
[e-mail]
STEVE CIKES (SBN 235413)
[e-mail]
RENNE SLOAN HOLTZMAN SAKAI LLP
555 Capitol Mall, Suite 600
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
SUPERIOR COURT OF CALIFORNIA,
COUNTY OF SHASTA (erroneously sued herein as
SHASTA COUNTY MARSHAL’S OFFICE), and JOEL DEAN

9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11
12

RENNE SLOAN H OLTZMAN SAKAI LLP
Attorneys at Law

13

JAIME SCHMIDT, DEBRA KNOWLES,
ELIZABETH SAMPSON, AND RYAN
HENRIOULLE,

14

Plaintiffs,

15

v.

16

Case No. 2:14-CV-02471-MCE
AMENDED1 JOINT STIPULATION AND
ORDER TO CONTINUE PRETRIAL
DEADLINES

SHASTA COUNTY MARSHAL’S OFFICE
AND JOEL DEAN,

17

Defendants.

18
19

Pursuant to Federal Rule of Civil Procedure 16(b) and Eastern District Local Rule 143,

20

Defendants Superior Court of California, County of Shasta2 and Joel Dean (collectively, “Defendants”)

21

and Plaintiffs Jaime Schmidt, Debra Knowles, Elizabeth Sampson and Ryan Henrioulle (“Plaintiffs”)

22

hereby stipulate and agree as follows.

23

WHEREAS, on October 21, 2014, Plaintiffs filed their Complaint (Docket No. 1) in this action.

24

In their Complaint, Plaintiffs allege that, while employed in the Marshal’s Office of the Superior Court of

25

California, County of Shasta, they were subjected to discrimination, harassment and retaliation, in

26
27
28

1

This amended stipulation and proposed order supersedes the stipulation and proposed order filed on
November 17, 2015 (Docket No. 13), in order to cure certain typographical errors in that document
pertaining to the proposed, new pretrial dates.
2
Erroneously sued herein as Shasta County Marshal’s Office.
-1JOINT STIPULATION AND ORDER TO CONTINUE PRETRIAL DEADLINES;
Case No. 2:14-CV-02471-MCE

1
2

violation of federal and state discrimination laws.
WHEREAS, on December 12, 2014, Defendants filed an Answer (Docket No. 6) to Plaintiffs’

3

Complaint, denying Plaintiffs’ claims in their entirety and asserting a variety of separate and additional

4

defenses.

5

WHEREAS, on April 10, 2015, the Court issued a Pretrial Scheduling Order (Docket No. 10),

6

setting various pretrial and trial deadlines, including a January 22, 2016 deadline for completing

7

discovery and a July 14, 2016 deadline for hearing any dispositive motions.

8
9

WHEREAS, to date, the parties have completed some discovery in this matter. For example, in
June 2015, the parties exchanged initial disclosures. Moreover, in September 2015, Defendants

10

propounded some written discovery on Plaintiffs, to which Plaintiffs, after receiving a three-week

11

extension, recently responded to.
WHEREAS, due to the fact that there are four individual Plaintiffs (each with their own separate

13
RENNE SLOAN H OLTZMAN SAKAI LLP
Attorneys at Law

12

sets of employment histories, factual allegations and legal claims), the parties do not believe they will be

14

able to complete discovery in this matter by the January 22, 2016 deadline. This is particularly so given

15

that in order to complete discovery by the current deadline, the parties would have to complete all

16

depositions within the next two months (notwithstanding the upcoming holidays).

17

WHEREAS, the parties anticipate that additional time will assist in their respective prosecution

18

and defense of this action and wish to continue the pretrial deadlines set forth in the Court’s Pretrial

19

Scheduling Order by approximately 90 days (see chart below). In light of the above circumstances, and

20

given that neither party has previously requested an extension of any of the pretrial dates set in this

21

matter, pursuant to Rule 16(b)(4) good cause exists for the relief requested herein.

22
23

NOW THEREFORE, based on the foregoing, the parties respectfully request that the Court
continue the pretrial deadlines in the following manner:

24

Subject

Current Deadline

Proposed New Deadline

25

Discovery Cut-Off

January 22, 2016

April 22, 2016

26

Settlement Conference Statements

February 11, 2016

May 12, 2016

27

Settlement Conference

February 18, 2016

May 19, 2016

Disclosure of Expert Witnesses

March 23, 2016

June 23, 2016

28

-2JOINT STIPULATION AND ORDER TO CONTINUE PRETRIAL DEADLINES;
Case No. 2:14-CV-02471-MCE

1

Dispositive Motions

July 14, 2016

October 20, 2016

2

Joint Final Pretrial Conference
Statement

November 9, 2016

January 19, 2017

Evidentiary/Procedural Motions

November 9, 2016

January 19, 2017

Trial Briefs

November 16, 2016

January 26, 2017

5

Final Pretrial Conference

December 1, 2016

February 9, 2017

6

Trial

January 23, 2017

April 3, 2017

3
4

7
8

IT IS SO STIPULATED.

9
10

Dated: December 1, 2015

RENNE SLOAN HOLTZMAN SAKAI LLP
By:

11
12

RENNE SLOAN H OLTZMAN SAKAI LLP
Attorneys at Law

13

Dated: December 1, 2015

LAW OFFICES OF ANTHONY J. POIDMORE
By:

14
15

/s/ Timothy G. Yeung
Timothy G. Yeung
Attorneys for Defendants

/s/ Anthony J. Poidmore (as authorized on 11/17/15)
Anthony J. Poidmore
Attorney for Plaintiffs

16
17
18

ORDER

19

The Court adopts the parties’ stipulation, with the dates modified by the Court, as its order.

20

IT IS SO ORDERED.

21

Dated: December 1, 2015

22
23
24
25
26
27
28
-3JOINT STIPULATION AND ORDER TO CONTINUE PRETRIAL DEADLINES;
Case No. 2:14-CV-02471-MCE