Ouapou-Lena v. Greenfield Care Center of Fairfield et al

Filing 17

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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1 2 3 4 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 5 6 7 8 9 10 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 11 12 13 14 15 16 17 18 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 19 UNITED STATES DISTRICT COURT 20 EASTERN DISTRICT OF CALIFORNIA 21 22 FABIENNE OUAPAOU-LENA, Plaintiff, 23 24 25 26 27 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 28 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 1 Plaintiff 2 FABIENNE OUAPAOU-LENA (“Plaintiff”) and Defendants 3 GREENFIELD CARE CENTER OF FAIRFIELD and EVA CARE GROUP, LLC (“Defendants”), 4 by and through their respective counsel of record, hereby stipulate as follows: 5 The pre-trial scheduling order in this matter sets a deadline of November 16, 2016, 6 for the parties to file dispositive motions, with a hearing date of December 14, 2016, and a trial date 7 of February 27, 2017. The parties seek to amend these dates and all related deadlines for good cause. 8 The parties have been diligently working to secure a mutually acceptable date and 9 location for the deposition of Plaintiff’s supervisor John Padama. Despite those efforts, and owing to 10 the burdens of counsels’ calendars, the deponent’s calendar, and the Thanksgiving holiday, the 11 parties were unable to determine any date prior to November 28, 2016, that was available to the 12 parties, counsel and Mr. Padama. Mr. Padama is set to be deposed on November 28, 2016, in Los 13 Angeles. In order to ensure that all necessary evidence is available for inclusion in a dispositive 14 motion, and to ensure Plaintiff’s counsel has sufficient time to defend such a motion, the parties 15 require an extension of the deadline to file dispositive motions. 16 Additionally, the parties have been engaged in settlement discussions and wish to 17 continue those efforts after Mr. Padama’s testimony has been secured and before a motion for 18 summary judgment is pending. Extension of the dispositive motion deadline will provide the parties 19 an opportunity to do so. A continuance of the dispositive motion hearing date, trial date and all 20 related deadlines would accommodate a continued deadline for filing dispositive motions. 21 Accordingly, the parties respectfully request: a dispositive motion filing deadline of 22 no earlier than December 13, 2016; a dispositive motion hearing date of no earlier than January 20, 23 2017; a joint pretrial statement filing deadline of no earlier than February 17, 2017; a final pretrial 24 conference date of no earlier than February 24, 2017; and a trial date of no earlier than April 3, 2017. 25 The parties do not anticipate any additional continuance of this matter. 26 //// 27 //// 28 //// //// 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 1 2 NOW, THEREFORE, IT IS HEREBY STIPULATED, by and between the parties 3 through their respective counsel, that the deadlines, hearing dates and conference dates currently set 4 in this matter be continued as follows: a dispositive motion filing deadline of no earlier than 5 December 13, 2016; a dispositive motion hearing date of no earlier than January 20, 2017 at 1:30 6 p.m.; a joint pretrial statement filing deadline of no earlier than February 17, 2017; a final pretrial 7 conference date of no earlier than February 24, 2017 at 10:00 a.m; and a trial date of no earlier than 8 April 3, 2017 at 9:00 a.m. 9 10 Dated: November 9, 2016 LITTLER MENDELSON, PC 11 12 /s/ John H. Adams, Jr. LINDBERGH PORTER BARBARA A. BLACKBURN JOHN H. ADAMS, JR. Attorneys for Defendants 13 14 15 16 17 SAMUEL RUDOLPH AND ASSOCIATES Dated: November 9, 2016 /s/ Samuel Rudolph (as authorized on 11/09/16) SAMUEL RUDOLPH Attorneys for Plaintiff 18 19 20 21 IT IS SO ORDERED. 22 23 24 Dated:_11/9/2016_____________________ /s/ John A. Mendez_______________________ ___________________________________ UNITED STATES DISTRICT COURT JUDGE 25 26 27 28 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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