Lopez v. Pre-employ.com, Inc.

Filing 15

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 1/11/18: The deadline to complete fact discovery is extended to March 1, 2018.(Kaminski, H)

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1 2 3 4 5 6 ROPERS, MAJESKI, KOHN & BENTLEY LAWRENCE BORYS (SBN 60625) TIMOTHY J. LEPORE (SBN 294247) 445 South Figueroa Street, Suite 3000 Los Angeles, CA 90071-1619 Telephone: (213) 312-2000 Facsimile: (213) 312-2001 Email: lawrence.borys@rmkb.com timothy.lepore@rmkb.com Attorneys for Defendant PRE-EMPLOY.COM, INC. A Professional Corporation Los Angeles Ropers Majeski Kohn & Bentley 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 ANTONIO A. LOPEZ, 12 CASE NO. 2:16-cv-02205-TLN-KJN 13 v. FIRST JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE FACT DISCOVERY 14 PRE-EMPLOY.COM, INC., Complaint Filed: September 15, 2016 Plaintiff, 15 Defendant. 16 17 Pursuant to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule 144(d), 18 Plaintiff Antonio A. Lopez (“Plaintiff”) and Defendant Pre-employ.com, Inc. (“Pre-employ”) 19 (collectively, the “Parties”), by and through their respective counsel of record, hereby agree and 20 stipulate to as follows: 21 1. On September 15, 2016, Plaintiff filed his Complaint. 22 2. On September 16, 2016, this Court issued Summons for Pre-employ and directed 23 24 25 26 27 28 Pre-employ to respond to Plaintiff’s Complaint within 21 days after service of the Summons. 3. On October 14, 2016, Plaintiff served the Summons and Complaint on Pre- employ. 4. On October 26, 2016, pursuant to Local Rule 144(a), Plaintiff and Defendant stipulated to Defendant’s first request for a 28-day extension to respond to Plaintiff’s Complaint. 5. 4825-8952-2235.1 On December 2, 2016, Pre-employ filed its Answer to Plaintiff’s Complaint. -1- FIRST STIPULATION TO EXTEND DATE TO COMPLETE DISCOVERY 1 2 6. On January 19, 2017, this Court issued its Pretrial Scheduling Order. ECF No. 10. The Pretrial Order set the following deadlines: Deadline to conduct and complete fact discovery: February 1, 2018; b. Deadline to disclose expert witnesses: April 5, 2018; 5 c. Deadline to hear dispositive motions by: August 9, 2018; 6 d. Final Pretrial Conference date: November 1, 2018; 7 A Professional Corporation Los Angeles a. 4 Ropers Majeski Kohn & Bentley 3 e. Joint Final Pretrial Conference date: October 25, 2018; 8 f. Trial date: January 7, 2019. 9 7. According to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule 10 144(d), the Parties request this Court to extend the deadline to complete fact discovery to March 11 1, 2018. 12 8. Good cause exists to grant this request because the Parties have been diligent in 13 conducting discovery and have been cooperative throughout the discovery period. To date, the 14 Parties have served and responded to written discovery, and Pre-employ has subpoenaed the 15 production of documents from three non-parties. In addition, on December 6, 2017, Pre-employ 16 issued subpoenas for deposition testimony from two non-parties, but is still coordinating dates to 17 depose the non-party witnesses. The Parties are also coordinating dates to take Plaintiff’s and Pre- 18 employ’s depositions at this time, and do not expect to finish taking all depositions prior to 19 February 1, 2017. Finally, extending the deadline to complete fact discovery will not require the 20 Court to extend any additional discovery or scheduling deadlines. 21 // 22 // 23 // 24 25 26 27 28 4825-8952-2235.1 -2- FIRST STIPULATION TO EXTEND DATE TO COMPLETE DISCOVERY 1 9. Accordingly, the Parties stipulate to the Court extending the discovery deadline 2 to complete fact discovery to March 1, 2018. 3 IT IS SO STIPULATED. 4 5 Dated: January 9, 2018 ROPERS, MAJESKI, KOHN & BENTLEY 6 A Professional Corporation Los Angeles Ropers Majeski Kohn & Bentley 7 By: /s/ Lawrence Borys LAWRENCE BORYS TIMOTHY J. LEPORE Attorneys for Defendant PRE-EMPLOY.COM, INC. 8 9 10 11 Dated: January 9, 2018 LAW OFFICES OF JOHN B. KEATING 12 13 By: /s/ Timothy J. Lepore (as authorized on January 9, 2018) JOHN B. KEATING Attorneys for Plaintiff ANTONIO A. LOPEZ 14 15 16 IT IS SO ORDERED. 17 18 19 Dated: January 11, 2018 20 21 Troy L. Nunley United States District Judge 22 23 24 25 26 27 28 4825-8952-2235.1 -3- FIRST STIPULATION TO EXTEND DATE TO COMPLETE DISCOVERY

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