Hoffman v. County of Butte

Filing 100

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 8/15/17 ORDERING that the 8/29/17 Discovery cut off is CONTINUED for 90 days, or to 11/27/2017. The expert disclosure date is continued to 60 days after 11/27/17. The supplemental expert disclosure date is continued to 90 days after 11/27/17. The dispositive motion cut-off is continued to 180 days from the new discovery cutoff of 11/27/17. (Mena-Sanchez, L)

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DAVID E. MASTAGNI, ESQ. (SBN 204244)
ISAAC S. STEVENS, ESQ. (SBN 251245)
ACE T. TATE, ESQ. (SBN 262015)
MASTAGNI HOLSTEDT
A Professional Corporation
1912 “I” Street
Sacramento, California 95811
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs

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MORIN I. JACOB, ESQ. (SBN 204598)
RICHARD C. BOLANOS, ESQ. (SBN 111343)
LISA S. CHARBONNEAU, ESQ. (SBN 245906)
LIEBERT CASSIDY WHITMORE
135 Main Street, 7th Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO

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DEBRA HOFFMAN on behalf of herself
and all similarly situated individuals,

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Plaintiffs,
v.
COUNTY OF BUTTE,

Case No.: 2:16-cv-01487-MCE-AC
Complaint Filed: June 30, 2016
STIPULATION AND ORDER TO EXTEND
DISCOVERY CUTOFF AND RELATED
DEADLINES FOR GOOD CAUSE

Defendant.

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Plaintiffs DEBRA HOFFMAN, et al. (“Plaintiffs”) and Defendant COUNTY OF BUTTE
(“Defendant”), by and through their respective counsel, hereby stipulate as follows:
WHEREAS, this putative collective action was filed on June 30, 2016, asserting that
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Stipulation and Order to Extend Discovery Cutoff

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Defendant violated the overtime payment provisions of the Fair Labor Standards Act (“FLSA”);
WHEREAS, On May 25, 2017 the Court referred this case to Magistrate Judge Gregory

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G. Hollows for settlement conference, and continued the discovery cutoff to August 29, 2017, as

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requested by counsel.

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WHEREAS, the parties are working diligently towards settlement of all issues in this case.

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The parties desire additional time to exhaust settlement efforts before engaging in further

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litigation and trial preparation.

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NOW THEREFORE, the Parties stipulate and respectfully submit that:

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Good cause exists to continue the August 29, 2017 discovery cut off for 90 days, or to

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November 27, 2017; continue the expert disclosure date to 60 days after November 27, 2017;

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continue the supplemental expert disclosure date to 90 days after November 27, 2017; and

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continue the dispositive motion cut-off to 180 days from the new discovery cutoff of November

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27, 2017.

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Dated: August 14, 2017

LIEBERT CASSIDY WHITMORE

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By: /s/ Lisa S. Charbonneau
MORIN I. JACOB, ESQ.
RICHARD C. BOLANOS, ESQ.
LISA S. CHARBONNEAU, ESQ
Attorneys for Defendant

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Dated: August 14, 2017

MASTAGNI HOLSTEDT

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By: /s/ David E. Mastagni
DAVID E. MASTAGNI, ESQ.
ISAAC S. STEVENS, ESQ.
ACE T. TATE, ESQ.
IAN SANGSTER, ESQ.
Attorneys for Plaintiffs

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Stipulation and Order to Extend Discovery Cutoff

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ORDER

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IT IS HEREBY ORDERED, based on the Parties’ stipulation and for good cause shown,
that:
The August 29, 2017 discovery cut off is continued for 90 days, or to November 27, 2017.

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The expert disclosure date is continued to 60 days after November 27, 2017. The supplemental

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expert disclosure date is continued to 90 days after November 27, 2017. The dispositive motion

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cut-off is continued to 180 days from the new discovery cutoff of November 27, 2017.

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IT IS SO ORDERED
Dated: August 15, 2017

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Stipulation and Order to Extend Discovery Cutoff