Evans v. Southern California Intergovernmental Training and Development Center

Filing 65

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr. on 2/4/2020 EXTENDING Time to 7/15/2020, for the parties to file dispositive motions. All other dates set forth in the operative scheduling order remain in effect. (York, M)

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1 2 3 4 5 6 7 8 9 10 Stephen R. Jaffe SBN 48539 The Jaffe Law Firm 101 California Street, Suite 2710 San Francisco, CA 94111 stephen.r.jaffe@jaffetriallaw.com 415.618.0100 Attorneys for Relator TAMARA EVANS McDOUGAL, LOVE, BOEHMER, FOLEY, LYON, CANLAS 8100 La Mesa Boulevard, Suite 200 La Mesa, CA 91942 (619) 440-4444 Attorneys for Defendant SOUTHERN CALIFORNIA INTERGOVERNMENTAL TRAINING AND DEVELOPMENT CENTER UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 13 UNITED STATES OF AMERICA ex rel. TAMARA EVANS, Case No.: 2:15-cv-00619-MCE 14 Relator, 15 16 17 18 STIPULATION AND ORDER SETTING NEW DATE BY WHICH DISPOSITIVE MOTIONS MUST BE FILED. vs. SOUTHERN CALIFORNIA INTERGOVERNMENTAL TRAINING AND DEVELOPMENT CENTER, et al. 19 Defendant. 20 21 The parties stipulate to the following facts: 22 1. The present scheduling order (Document 47) requires the parties to file dispositive 23 motions no later than 180 days from close of discovery on September 20, 2019, or by 24 March 18 , 2020. 25 2. Stephen R. Jaffe, counsel for the relator in this action, is lead counsel for the relators 26 in United States of America ex rel Rose et al. v Stephens Institute et al, N. Dist. CA 27 Case No. 09-CIV-5966-PJH ( hereafter “US v AAU”). 28 STIPULATION AND ORDER 2 1 3. US v. AAU is in its eleventh year of litigation. It has been contentiously litigated in 2 the District Court, the Ninth Circuit Court of Appeals and was the subject of an 3 unsuccessful petition for writ of certiorari by the defendant in the United States 4 Supreme Court. 5 6 7 8 9 10 4. US v AAU is set for jury trial on May 5, 2020. However, pretrial documents and materials are due to be filed with the District Court commencing March 5, 2020. 5. Under the present scheduling order, it is impossible for Mr. Jaffe to prepare for trial in US v AAU and, at the same time, prepare dispositive motions and/or oppose defendant’s dispositive motion, if any, in this case. 11 6. No party will be prejudiced by the rescheduling order sought by this stipulation. 12 7. The parties agree this court may make an Order resetting the last date to file 13 dispositive motions in this action from March 18, 2020 to July 15, 2020. 14 15 16 17 18 McDOUGAL, LOVE, BOEHMER, FOLEY, LYON, CANLAS THE JAFFE LAW FIRM By:_______/s/_____________ John Petze Attorneys for Southern California Intergovernmental Training and Development Center By:_____________/s/_____________________ Stephen R. Jaffe Attorneys for Realtor EVANS 19 ORDER 20 The foregoing stipulation having been presented to the Court and good cause appearing, 21 the last day for the parties to file dispositive motions herein is continued from March 18, 2020 to 22 July 15, 2020. All other dates set forth in the operative scheduling order remain in effect. 23 24 25 IT IS SO ORDERED. Dated: February 4, 2020 26 27 28 STIPULATION AND ORDER 2

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