Callahan v. Pinnacle Property Management Services, LLC et al
Filing
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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)
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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
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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
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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BRENNA CALLAHAN,
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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.
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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
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WHEREAS, PINNACLE PROPERTY MANAGEMENT SERVICES, LLC and
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PINNACLE PROPERTY MANAGEMENT SERVICES PIER 70 (collectively referred to as
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“Defendants”) and BRENNA CALLAHAN (“Plaintiff”) (collectively the “Parties”);
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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);
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WHEREAS, the Pretrial Scheduling Order requires the Parties to prepare and submit to
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the Court the Rule 26(f)(3) discovery plan (“Discovery Plan”) within 14 days of the Parties’
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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.
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THEREFORE, good cause exists for this stipulation and order to continue the deadline for
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filing the Discovery Plan pursuant to the Pretrial Scheduling Order so that the Parties may explore
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potential settlement without concurrently incurring further litigation costs and fees.
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WHEREFORE, the Parties hereby jointly stipulate and request an order as follows:
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The current deadline of October 17, 2016, to file a Discovery Plan pursuant to Rule
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26(f)(3) will be continued until December 16, 2016 (60 additional days).
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IT IS SO STIPULATED.
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Dated: October 12, 2016
Shimoda Law Corp.
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By:/s/ Galen T. Shimoda [as authorized. on 10.12.16]
GALEN T. SHIMODA
ERIKA R. C. SEMBRANO
Attorneys for Plaintiff
BRENNA CALLAHAN
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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
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Dated: October 12, 2016
JACKSON LEWIS P.C.
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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
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ORDER
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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
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4826-4294-0218, v. 1
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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
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