Tugas v. Hill-Rom Company, Inc.

Filing 10

STIPULATION and ORDER signed by District Judge John A. Mendez on 01/15/16 ORDERING that the parties shall meet and confer and file their joint status report by 02/18/16. (Benson, A)

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION

101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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GERMAN TUGAS, on behalf of himself, all
others similarly situated, and on behalf of the
general public,

Case No. 2:15-cv-02426-JAM-CKD
Assigned to The Honorable John A. Mendez

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Plaintiff,

STIPULATION REQUESTING
EXTENSION OF CURRENT DEADLINE
TO CONDUCT THE PARTIES’ RULE
26(F) CONFERENCE AND TO FILE THE
JOINT STATUS REPORT

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v.
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HILL-ROM COMPANY, INC., and
DOES 1-100, inclusive,
Defendants.

Complaint filed August 24, 2015
First Amended Complaint filed December 21,
2015

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STIPULATION REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD

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William Turley (SBN: 122408)
[e-mail]
David Mara (SBN: 230498)
[e-mail]
The Turley Law Firm, APLC
7428 Trade Street
San Diego, CA 92121
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiff
GERMAN TUGAS

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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Joan B. Tucker Fife (SBN: 144572)
[e-mail]
Emily C. Schuman (SBN: 271915)
[e-mail]
WINSTON & STRAWN LLP
101 California Street, Suite 3900
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant
HILL-ROM COMPANY, INC.

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STIPULATION REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD

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THIS STIPULATION is hereby entered into by and between Plaintiff German Tugas and

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Defendant Hill-Rom Company, Inc. (“Hill-Rom”) pursuant to Eastern District of California Local

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Rule 143(a)(1).

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RECITALS

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WHEREAS, the Court issued an Order on November 23, 2015 requiring the parties to meet

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and confer pursuant to Federal Rule of Civil Procedure 26(f) and to file a joint status report by

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January 19, 2016 (dkt. 2);

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WHEREAS, Plaintiff filed his First Amended Complaint on December 21, 2015 (dkt. 6) that

101 California Street
San Francisco, CA 94111-5802

contained new allegations not previously set forth in the original Complaint (dkt. 1);

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Winston & Strawn LLP

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WHEREAS, Hill-Rom timely answered on January 7, 2016 (dkt. 7);

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WHEREAS, the parties communicated on January 14, 2016 and agreed that a more

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comprehensive meet and confer pursuant to Rule 26(f) and a more tailored joint status report could

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be submitted if the parties had additional time to review the case as alleged in Plaintiff’s First

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Amended Complaint;

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WHEREAS, the parties do not seek this continuance for purposes of delay, but, rather, to
efficiently and thoroughly manage the case in regards to timelines, substance, and procedure;

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NOW, THEREFORE, the parties hereby stipulate to, and request that the Court order, that

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the parties’ deadline to meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and their

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deadline to file a joint status report shall be extended 30 days, to February 18, 2016.

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IT IS SO STIPULATED.

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STIPULATION REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD

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Dated: January 14, 2016

THE TURLEY LAW FIRM, APLC

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By:

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/s/ William Turley (as authorized on January 14, 2016)
William Turley

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Dated: January 14, 2016

WINSTON & STRAWN LLP

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By:

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/s/ Emily C. Schuman
Emily C. Schuman

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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ORDER

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Having considered the Joint Stipulation submitted by the parties, and for good cause

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appearing therefore, IT IS SO ORDERED that the parties shall meet and confer pursuant to Federal

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Rule of Civil Procedure 26(f) and file their joint status report by February 18, 2016.

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Dated: 1/15/2016

/s/ John A. Mendez________
Honorable John A. Mendez
United States District Court
Eastern District of California

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STIPULATION REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD