Ouapou-Lena v. Greenfield Care Center of Fairfield et al
Filing
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STIPULATION and ORDER signed by District Judge John A. Mendez on 11/09/2016 ORDERING that the deadlines, hearing dates and conference dates currently set in this matter are continued as follows: Dispositive Motions filed by 12/13/2016; Dispositive Mo tion Hearing date shall be 01/20/2017 at 1:30 PM; a Joint Pretrial Statement shall be filed by 02/17/2017; Final Pretrial Conference set for 2/24/2017 at 10:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez; Jury Trial set for 4/3/2017 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Butolph, J)
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SAMUEL B. RUDOLPH, Bar No. 161149
KIMBERLY R. CARVER, Bar No. 214755
SAMUEL RUDOLPH & ASSOCIATES
22764 Main Street
Hayward, CA 94541
Telephone:
510.886.4876
Fax No.
415.692.8166
Email:
srudolph1@sbcglobal.net
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Attorneys for Plaintiff
FABIENNE OUAPOU-LENA
LINDBERGH PORTER, Bar No. 100091
LITTLER MENDELSON, P.C.
333 Bush Street
34th Floor
San Francisco, CA 94104
Telephone:
415.433.1940
Fax No.:
415.399.8490
Email: lporter@littler.com
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BARBARA A. BLACKBURN, Bar No. 253731
JOHN H. ADAMS, JR., Bar No. 253341
LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
Telephone:
916.830.7200
Facsimile:
916.561.0828
Email: bblackburn@littler.com
jhadams@littler.com
Attorneys for Defendants
GREENFIELD CARE CENTER OF FAIRFIELD
AND EVA CARE GROUP, LLC
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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FABIENNE OUAPAOU-LENA,
Plaintiff,
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v.
GREENFIELD CARE CENTER OF
FAIRFIELD, EVA CARE GROUP, LLC,
DOES 1 - 50 INCLUSIVE,
Defendants.
Case No. 2:15-cv-00721-JAM-DB
STIPULATION TO EXTEND DEADLINE
FOR FILING DISPOSITIVE MOTIONS,
TRIAL DATE AND RELATED
DEADLINES
Discovery Cutoff:
Trial Date:
Motion Deadline:
Magistrate Judge:
October 31, 2016
February 27, 2016
November 16, 2016
Deborah Barnes
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LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
916.830.7200
FIRMWIDE:143817343.1 052068.1029
Case No. 2:15-cv-00721-JAM-DB
STIPULATION TO EXTEND DEADLINE FOR FILING DISPOSITIVE MOTIONS,
TRIAL DATE AND RELATED DEADLINES
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Plaintiff
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FABIENNE
OUAPAOU-LENA
(“Plaintiff”)
and
Defendants
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GREENFIELD CARE CENTER OF FAIRFIELD and EVA CARE GROUP, LLC (“Defendants”),
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by and through their respective counsel of record, hereby stipulate as follows:
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The pre-trial scheduling order in this matter sets a deadline of November 16, 2016,
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for the parties to file dispositive motions, with a hearing date of December 14, 2016, and a trial date
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of February 27, 2017. The parties seek to amend these dates and all related deadlines for good cause.
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The parties have been diligently working to secure a mutually acceptable date and
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location for the deposition of Plaintiff’s supervisor John Padama. Despite those efforts, and owing to
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the burdens of counsels’ calendars, the deponent’s calendar, and the Thanksgiving holiday, the
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parties were unable to determine any date prior to November 28, 2016, that was available to the
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parties, counsel and Mr. Padama. Mr. Padama is set to be deposed on November 28, 2016, in Los
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Angeles. In order to ensure that all necessary evidence is available for inclusion in a dispositive
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motion, and to ensure Plaintiff’s counsel has sufficient time to defend such a motion, the parties
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require an extension of the deadline to file dispositive motions.
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Additionally, the parties have been engaged in settlement discussions and wish to
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continue those efforts after Mr. Padama’s testimony has been secured and before a motion for
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summary judgment is pending. Extension of the dispositive motion deadline will provide the parties
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an opportunity to do so. A continuance of the dispositive motion hearing date, trial date and all
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related deadlines would accommodate a continued deadline for filing dispositive motions.
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Accordingly, the parties respectfully request: a dispositive motion filing deadline of
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no earlier than December 13, 2016; a dispositive motion hearing date of no earlier than January 20,
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2017; a joint pretrial statement filing deadline of no earlier than February 17, 2017; a final pretrial
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conference date of no earlier than February 24, 2017; and a trial date of no earlier than April 3, 2017.
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The parties do not anticipate any additional continuance of this matter.
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LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
916.830.7200
STIPULATION TO EXTEND DEADLINE FOR FILING DISPOSITIVE MOTIONS,
Case No. 2:15-cv-00721-JAM-DB
TRIAL DATE AND RELATED DEADLINES
FIRMWIDE:143817343.1 052068.1029
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NOW, THEREFORE, IT IS HEREBY STIPULATED, by and between the parties
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through their respective counsel, that the deadlines, hearing dates and conference dates currently set
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in this matter be continued as follows: a dispositive motion filing deadline of no earlier than
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December 13, 2016; a dispositive motion hearing date of no earlier than January 20, 2017 at 1:30
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p.m.; a joint pretrial statement filing deadline of no earlier than February 17, 2017; a final pretrial
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conference date of no earlier than February 24, 2017 at 10:00 a.m; and a trial date of no earlier than
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April 3, 2017 at 9:00 a.m.
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Dated: November 9, 2016
LITTLER MENDELSON, PC
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/s/ John H. Adams, Jr.
LINDBERGH PORTER
BARBARA A. BLACKBURN
JOHN H. ADAMS, JR.
Attorneys for Defendants
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SAMUEL RUDOLPH AND ASSOCIATES
Dated: November 9, 2016
/s/ Samuel Rudolph (as authorized on
11/09/16)
SAMUEL RUDOLPH
Attorneys for Plaintiff
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IT IS SO ORDERED.
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Dated:_11/9/2016_____________________
/s/ John A. Mendez_______________________
___________________________________
UNITED STATES DISTRICT COURT JUDGE
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LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
916.830.7200
FIRMWIDE:143817343.1 052068.1029
STIPULATION
2.
Case No. 2:15-cv-00721-JAM-DB
TO EXTEND DEADLINE FOR FILING DISPOSITIVE MOTIONS,
TRIAL DATE AND RELATED DEADLINES
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