Evans v. Southern California Intergovernmental Training and Development Center

Filing 41

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 1/10/2018 EXTENDING the deadline for Discovery to 4/6/2018. (Hunt, G)

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1 2 3 4 5 6 Steven E. Boehmer, Esq. (#144817) Amanda R. Abeln-Overs, Esq. (#290309) McDOUGAL LOVE BOEHMER FOLEY LYON & CANLAS 8100 La Mesa Blvd., Suite 200 La Mesa, California 91942 Telephone: (619) 440-4444 Facsimile: (619) 440-4907 EXEMPT FROM FILING FEES PURSUANT TO GOVERNMENT CODE SECTION 6103 Attorneys for Defendant, SOUTHERN CALIFORNIA INTERGOVERNMENTAL TRAINING AND DEVELOPOMENT CENTER 7 8 UNITES STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 UNITED STATES OF AMERICA Case No.: 2:15-cv-00619-MCE-CKD and THE STATE OF CALIFORNIA ex ret. TAMARA EVANS, STIPULATION TO CONTINUE THE DISCOVERY DEADLINE; ORDER Plaintiff/Relator, THEREON v. SOUTHERN CALIFORNIA INTERGOVERNMENTAL TRAINING AND DEVELOPMENT CENTER, and DOES 1-10, Judge: Hon. Morrison C. England, Jr. Defendant(s). 17 18 TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR 19 THE EASTERN DISTRICT OF CALIFORNIA, AND TO ALL PARTIES 20 THROUGH THERE COUNSEL OF RECORD HEREIN: 21 Plaintiff-realtor Tamara Evans (“relator”) and defendant Southern California 22 Governmental Training and Development Center (“defendant”), by an through 23 their counsel of record, hereby recite and stipulate, subject to the Court’s approval 24 as provided for herein, as follows: 25 On March 19, 2015, plaintiff-relator Tamara Evans (“relator”) filed the 26 instant case under seal. (ECF No. 1). Following the decision of the United States 27 not to intervene, the court ordered the case unsealed on January 6, 2017. (ECF 28 1 STIPULATION TO CONTINUE THE DISCOVERY DEADLINE; ORDER THEREON 2:15-cv-00619-MCE-CKD 1 Nos. 22-23.) Relator served defendant on January 10, 2017 with the summons and 2 complaint as well as a copy of this court’s January 6, 2017 initial pretrial 3 scheduling order requiring discovery be completed by March 18, 2016. (ECF No. 4 26.) Because defendant was not served until after the discovery cut-off, the parties 5 stipulated to amending the initial pretrial scheduling order to require all discovery, 6 except expert discovery, be completed on January 6, 2018. (ECF No. 26.) In response to relator’s complaint, defendant filed a motion to dismiss the 7 8 relator’s claims under the California False Claims Act and the court issued its order 9 granting the motion on April 26, 2017. (ECF No. 35.) While the Court was 10 considering the motion to dismiss, the parties delayed discovery in an effort to 11 limit costs and litigate the action efficiently. The parties now require additional 12 time to complete discovery, including three depositions. 13 The parties submit that good cause exists for a continuance of the fact 14 discovery deadline and have agreed to continue the fact discovery deadline to April 15 6, 2018 in order to allow the parties to complete fact discovery and attempt to 16 resolve this action informally. 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 2 STIPULATION TO CONTINUE THE DISCOVERY DEADLINE; ORDER THEREON 2:15-cv-00619-MCE-CKD 1 IT IS HEREBY STIPULATED by and between relator and defendant, by 2 and through their attorneys of record, that the initial pretrial scheduling order be 3 amended to require that all discovery, with the exception of expert discovery, shall 4 be completed no later than April 6, 2018. 5 6 IT IS SO STIPULATED. Dated: January 10, 2018 7 MCDOUGAL LOVE ECKIS BOEHMER & FOLEY 8 By: /s/ Amanda R. Abeln-Over ____________ Steven E. Boehmer Amanda R. Abeln-Overs Attorneys for Defendant, SOUTHERN CALIFORNIA INTERGOVERNMENTAL TRAINING AND DEVELOPMENT CENTER 9 10 11 12 13 14 Dated: January 10, 2018 THE JAFFE LAW FIRM 15 16 By: /s/ Stephen R. Jaffe (as authorized on January 8, 2018) Stephen R. Jaffe Attorney for Plaintiff/Relator TAMARA EVANS 17 18 19 ORDER 20 21 Pursuant to the terms of the foregoing stipulation, the Court extends the fact 22 discovery deadline to April 6, 2018. All other related deadlines in the Initial 23 Pretrial Scheduling Order will be based on this extended date. 24 25 IT IS SO ORDERED. Dated: January 10, 2018 26 27 28 3 STIPULATION TO CONTINUE THE DISCOVERY DEADLINE; ORDER THEREON 2:15-cv-00619-MCE-CKD

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