Callahan v. Pinnacle Property Management Services, LLC et al

Filing 14

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 10/21/16 ORDERING that the Parties have until 12/16/16 to file a discovery plan.(Washington, S)

Download PDF
1 2 3 4 5 6 7 Galen T. Shimoda (SBN 226752) Justin P. Rodriguez (SBN 278275) Erika R. C. Sembrano (SBN 306635) Shimoda Law Corp. 9401 East Stockton Blvd., Suite 200 Elk Grove, CA 95624 Telephone: (916) 525-0716 Facsimile: (916) 760-3733 Email: attorney@shimodalaw.com jrodriguez@shimodalaw.com esembrano@shimodalaw.com Attorneys for Plaintiff BRENNA CALLAHAN 8 9 10 11 12 13 14 15 JACKSON LEWIS P.C. JAMES T. JONES (SBN 167967) HEATH A. HAVEY (SBN 244087) 400 Capitol Mall, Suite 1600 Sacramento, California 95814 Telephone: (916) 341-0404 Facsimile: (916) 341-0141 Email: jonesj@jacksonlewis.com heath.havey@jacksonlewis.com Attorneys for Defendants PINNACLE PROPERTY MANAGEMENT SERVICES, LLC and PINNACLE PROPERTY MANAGEMENT SERVICES PIER 70 16 17 UNITED STATES DISTRICT COURT 18 EASTERN DISTRICT OF CALIFORNIA 19 20 BRENNA CALLAHAN, 21 22 23 24 25 26 27 Case No. 2:16-cv-01862-MCE-EFB Plaintiff, JOINT STIPULATION TO EXTEND DATE TO FILE JOINT DISCOVERY PLAN; ORDER vs. PINNACLE PROPERTY MANAGEMENT SERVICES, LLC, a Delaware Limited Liability Company; PINNACLE PROPERTY MANAGEMENT SERVICES PIER 70, a business organization, form unknown; and DOES 1 to 100, inclusive, Complaint Filed: 06/23/2016 Removal Filed: 08/05/2016 Trial Date: TBA Defendants. 28 1 JOINT STIPULATION TO EXTEND DATE TO FILE JOINT DISCOVERY PLAN; ORDER Callahan v. Pinnacle Property Management Services Case No. 2:16-cv-01862-MCE-EFB 1 WHEREAS, PINNACLE PROPERTY MANAGEMENT SERVICES, LLC and 2 PINNACLE PROPERTY MANAGEMENT SERVICES PIER 70 (collectively referred to as 3 “Defendants”) and BRENNA CALLAHAN (“Plaintiff”) (collectively the “Parties”); 4 5 6 7 WHEREAS, the Court filed its Revised Initial Pretrial Scheduling Order (“Pretrial Scheduling Order”) on August 12, 2016; WHEREAS, the Pretrial Scheduling Order requires the Parties to confer within 60 days of the date of removal as required by Federal Rule of Civil Procedure 26(f); 8 WHEREAS, the Pretrial Scheduling Order requires the Parties to prepare and submit to 9 the Court the Rule 26(f)(3) discovery plan (“Discovery Plan”) within 14 days of the Parties’ 10 11 12 conference, which deadline is October 17, 2016; and WHEREAS, the Parties have conferred and mutually desire to explore early resolution of this action and avoid unnecessary expenditure of time and fees on formal litigation. 13 THEREFORE, good cause exists for this stipulation and order to continue the deadline for 14 filing the Discovery Plan pursuant to the Pretrial Scheduling Order so that the Parties may explore 15 potential settlement without concurrently incurring further litigation costs and fees. 16 WHEREFORE, the Parties hereby jointly stipulate and request an order as follows: 17 The current deadline of October 17, 2016, to file a Discovery Plan pursuant to Rule 18 26(f)(3) will be continued until December 16, 2016 (60 additional days). 19 IT IS SO STIPULATED. 20 Dated: October 12, 2016 Shimoda Law Corp. 21 22 23 24 By:/s/ Galen T. Shimoda [as authorized. on 10.12.16] GALEN T. SHIMODA ERIKA R. C. SEMBRANO Attorneys for Plaintiff BRENNA CALLAHAN 25 26 27 28 2 JOINT STIPULATION TO EXTEND DATE TO FILE JOINT DISCOVERY PLAN; ORDER Callahan v. Pinnacle Property Management Services Case No. 2:16-cv-01862-MCE-EFB 1 Dated: October 12, 2016 JACKSON LEWIS P.C. 2 By: /s/ Heath A. Havey JAMES T. JONES HEATH A. HAVEY Attorneys for Defendants PINNACLE PROPERTY MANAGEMENT SERVICES, LLC and PINNACLE PROPERTY MANAGEMENT SERVICES PIER 70 3 4 5 6 7 ORDER 8 9 10 11 12 13 14 Pursuant to the parties’ stipulation and good cause appearing, in order to promote settlement efforts, IT IS HEREBY ORDERED AS FOLLOWS: The terms of the above Stipulation are hereby approved and adopted. The Parties have an additional sixty days (until December 16, 2016) to file a discovery plan pursuant to Rule 26(f)(3). IT IS SO ORDERED. Dated: October 21, 2016 15 16 17 18 19 4826-4294-0218, v. 1 20 21 22 23 24 25 26 27 28 3 JOINT STIPULATION TO EXTEND DATE TO FILE JOINT DISCOVERY PLAN; ORDER Callahan v. Pinnacle Property Management Services Case No. 2:16-cv-01862-MCE-EFB

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?