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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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: [phone]
Facsimile: [phone]

EXEMPT FROM FILING FEES
PURSUANT TO GOVERNMENT
CODE SECTION 6103

Attorneys for Defendant, SOUTHERN CALIFORNIA
INTERGOVERNMENTAL TRAINING AND
DEVELOPOMENT CENTER

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UNITES STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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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).

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TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR

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THE EASTERN DISTRICT OF CALIFORNIA, AND TO ALL PARTIES

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THROUGH THERE COUNSEL OF RECORD HEREIN:

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Plaintiff-realtor Tamara Evans (“relator”) and defendant Southern California

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Governmental Training and Development Center (“defendant”), by an through

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their counsel of record, hereby recite and stipulate, subject to the Court’s approval

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as provided for herein, as follows:

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On March 19, 2015, plaintiff-relator Tamara Evans (“relator”) filed the

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instant case under seal. (ECF No. 1). Following the decision of the United States

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not to intervene, the court ordered the case unsealed on January 6, 2017. (ECF

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STIPULATION TO CONTINUE THE DISCOVERY DEADLINE; ORDER THEREON

2:15-cv-00619-MCE-CKD

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Nos. 22-23.) Relator served defendant on January 10, 2017 with the summons and

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complaint as well as a copy of this court’s January 6, 2017 initial pretrial

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scheduling order requiring discovery be completed by March 18, 2016. (ECF No.

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26.) Because defendant was not served until after the discovery cut-off, the parties

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stipulated to amending the initial pretrial scheduling order to require all discovery,

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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

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relator’s claims under the California False Claims Act and the court issued its order

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granting the motion on April 26, 2017. (ECF No. 35.) While the Court was

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considering the motion to dismiss, the parties delayed discovery in an effort to

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limit costs and litigate the action efficiently. The parties now require additional

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time to complete discovery, including three depositions.

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The parties submit that good cause exists for a continuance of the fact

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discovery deadline and have agreed to continue the fact discovery deadline to April

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6, 2018 in order to allow the parties to complete fact discovery and attempt to

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resolve this action informally.

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STIPULATION TO CONTINUE THE DISCOVERY DEADLINE; ORDER THEREON

2:15-cv-00619-MCE-CKD

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IT IS HEREBY STIPULATED by and between relator and defendant, by

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and through their attorneys of record, that the initial pretrial scheduling order be

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amended to require that all discovery, with the exception of expert discovery, shall

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be completed no later than April 6, 2018.

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IT IS SO STIPULATED.
Dated: January 10, 2018

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MCDOUGAL LOVE ECKIS
BOEHMER & FOLEY

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By: /s/ Amanda R. Abeln-Over ____________
Steven E. Boehmer
Amanda R. Abeln-Overs
Attorneys for Defendant, SOUTHERN
CALIFORNIA INTERGOVERNMENTAL
TRAINING AND DEVELOPMENT
CENTER

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Dated: January 10, 2018

THE JAFFE LAW FIRM

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By: /s/ Stephen R. Jaffe (as authorized on
January 8, 2018)
Stephen R. Jaffe
Attorney for Plaintiff/Relator
TAMARA EVANS

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ORDER

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Pursuant to the terms of the foregoing stipulation, the Court extends the fact

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discovery deadline to April 6, 2018. All other related deadlines in the Initial

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Pretrial Scheduling Order will be based on this extended date.

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IT IS SO ORDERED.
Dated: January 10, 2018

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STIPULATION TO CONTINUE THE DISCOVERY DEADLINE; ORDER THEREON

2:15-cv-00619-MCE-CKD