Lopez v. Pre-employ.com, Inc.
Filing
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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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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
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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ANTONIO A. LOPEZ,
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CASE NO. 2:16-cv-02205-TLN-KJN
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v.
FIRST JOINT STIPULATION TO
EXTEND DEADLINE TO COMPLETE
FACT DISCOVERY
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PRE-EMPLOY.COM, INC.,
Complaint Filed: September 15, 2016
Plaintiff,
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Defendant.
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Pursuant to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule 144(d),
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Plaintiff Antonio A. Lopez (“Plaintiff”) and Defendant Pre-employ.com, Inc. (“Pre-employ”)
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(collectively, the “Parties”), by and through their respective counsel of record, hereby agree and
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stipulate to as follows:
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1.
On September 15, 2016, Plaintiff filed his Complaint.
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2.
On September 16, 2016, this Court issued Summons for Pre-employ and directed
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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.
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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.
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4825-8952-2235.1
On December 2, 2016, Pre-employ filed its Answer to Plaintiff’s Complaint.
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FIRST STIPULATION TO EXTEND DATE
TO COMPLETE DISCOVERY
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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;
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c.
Deadline to hear dispositive motions by:
August 9, 2018;
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d.
Final Pretrial Conference date:
November 1, 2018;
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A Professional Corporation
Los Angeles
a.
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Ropers Majeski Kohn & Bentley
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e.
Joint Final Pretrial Conference date:
October 25, 2018;
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f.
Trial date:
January 7, 2019.
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7.
According to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule
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144(d), the Parties request this Court to extend the deadline to complete fact discovery to March
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1, 2018.
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8.
Good cause exists to grant this request because the Parties have been diligent in
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conducting discovery and have been cooperative throughout the discovery period. To date, the
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Parties have served and responded to written discovery, and Pre-employ has subpoenaed the
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production of documents from three non-parties. In addition, on December 6, 2017, Pre-employ
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issued subpoenas for deposition testimony from two non-parties, but is still coordinating dates to
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depose the non-party witnesses. The Parties are also coordinating dates to take Plaintiff’s and Pre-
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employ’s depositions at this time, and do not expect to finish taking all depositions prior to
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February 1, 2017. Finally, extending the deadline to complete fact discovery will not require the
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Court to extend any additional discovery or scheduling deadlines.
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4825-8952-2235.1
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FIRST STIPULATION TO EXTEND DATE
TO COMPLETE DISCOVERY
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9.
Accordingly, the Parties stipulate to the Court extending the discovery deadline
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to complete fact discovery to March 1, 2018.
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IT IS SO STIPULATED.
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Dated: January 9, 2018
ROPERS, MAJESKI, KOHN & BENTLEY
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A Professional Corporation
Los Angeles
Ropers Majeski Kohn & Bentley
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By: /s/ Lawrence Borys
LAWRENCE BORYS
TIMOTHY J. LEPORE
Attorneys for Defendant
PRE-EMPLOY.COM, INC.
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Dated: January 9, 2018
LAW OFFICES OF JOHN B. KEATING
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By: /s/ Timothy J. Lepore
(as authorized on January 9, 2018)
JOHN B. KEATING
Attorneys for Plaintiff
ANTONIO A. LOPEZ
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IT IS SO ORDERED.
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Dated: January 11, 2018
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Troy L. Nunley
United States District Judge
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4825-8952-2235.1
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FIRST STIPULATION TO EXTEND DATE
TO COMPLETE DISCOVERY
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