Lopez v. Pre-employ.com, Inc.

Filing 18

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 3/28/2018 ORDERING the deadline to disclose expert witnesses is EXTENDED to 5/1/2018. (Zignago, K.)

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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:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
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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Plaintiff,

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v.

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PRE-EMPLOY.COM, INC.,

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CASE NO. 2:16-cv-02205-TLN-KJN
SECOND STIPULATION TO AMEND
PRE-TRIAL SCHEDULING ORDER TO
EXTEND THE DEADLINE TO DISCLOSE
EXPERT WITNESSES
Complaint Filed: September 15, 2016

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. ECF No. 1.

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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.
4.

On October 26, 2016, pursuant to Local Rule 144(a), Plaintiff and Defendant

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stipulated to Defendant’s first request for a 28-day extension to respond to Plaintiff’s Complaint.

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ECF No. 4.
4818-1958-3839.2

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SECOND STIPULATION TO AMEND
PRE-TRIAL SCHEDULING ORDER

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On January 19, 2017, this Court issued its Pretrial Scheduling Order. ECF No. 10.

No. 7.

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On December 2, 2016, Pre-employ filed its Answer to Plaintiff’s Complaint. ECF

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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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A Professional Corporation
Los Angeles

a.

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Ropers Majeski Kohn & Bentley

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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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e.

Joint Final Pretrial Conference date:

October 25, 2018;

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f.

Trial date:

January 7, 2019.

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7.

On January 11, 2018, this Court issued an order extending fact discovery to March

1, 2018. ECF No. 15.

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8.

According to Federal Rules of Civil Procedure, Rule 16(b)(4), and Local Rule

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144(d), the Parties now request this Court to extend the deadline to make expert disclosures to

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May 1, 2018.

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9.

Good cause exists to grant this request to allow this extension of the expert

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disclosure deadline for a short period consistent with the prior extension of the discovery cut off

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in that the extension will allow reasonable time for expert analysis of the later discovery. In

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particular, the parties have not yet completed all of the discovery noticed to be completed

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pursuant to the revised discovery cut off deadline of March 1, 2018 and do not expect the

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remaining depositions to be completed until April 13, 2018, well after the current expert

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disclosure deadline of April 5, 2018. Therefore, the Parties wish to extend the initial deadline to

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disclose expert witnesses to May 1, 2018.

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//

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//

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//

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4818-1958-3839.2

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SECOND STIPULATION TO AMEND
PRE-TRIAL SCHEDULING ORDER

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10.

Accordingly, the Parties stipulate to the Court extending the deadline to disclose

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expert witnesses to May 1, 2018.

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IT IS SO STIPULATED.

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Dated: March 26, 2018

ROPERS, MAJESKI, KOHN & BENTLEY

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A Professional Corporation
Los Angeles

Ropers Majeski Kohn & Bentley

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By: /s/ Timothy J. Lepore
LAWRENCE BORYS
TIMOTHY J. LEPORE
Attorneys for Defendant
PRE-EMPLOY.COM, INC.

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Dated: March 26, 2018

LAW OFFICES OF JOHN B. KEATING

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By: /s/ John B. Keating
(as authorized on March 26, 2018)
JOHN B. KEATING
Attorneys for Plaintiff
ANTONIO A. LOPEZ

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IT IS SO ORDERED.

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Dated: March 28, 2018

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Troy L. Nunley
United States District Judge

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4818-1958-3839.2

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SECOND STIPULATION TO AMEND
PRE-TRIAL SCHEDULING ORDER