Ruffino v. United States of America

Filing 26

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 4/3/18 ORDERING that the Amended Scheduling Order is APPROVED. Defendant shall file its jurisdictional Motion on or before 5/18/18, and the hearing on Motion is moved from 4/20/18 to 6/15/18 at 10:00 a.m., in Courtroom No. 3. Discovery is stayed as of 3/23/18. The remainder of the Court's scheduling order (ECF No. 24 remains in effect. (Mena-Sanchez, L)

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Frederick Schenk, SBN 086392
[e-mail]
Angela Jae Chun, SBN 248571
[e-mail]
Jillian F. Hayes, SBN 297536
[e-mail]
CASEY GERRY SCHENK
FRANCAVILLA BLATT & PENFIELD, LLP
110 Laurel Street
San Diego, CA 92101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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GIANFRANCO RUFFINO, an individual,
Plaintiff,

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Judge: Hon. Kimberly J. Mueller
Dept: Courtroom 3, 15th Floor

v.
UNITED STATES OF AMERICA; and DOES
1 through 100, inclusive,

STIPULATION AND JOINT REQUEST
TO MODIFY PRETRIAL SCHEDULING
ORDER; ORDER

Defendants.

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CASE NO. 2:16-CV-02719-KLM-CKD

Plaintiff Gianfranco Ruffino and Defendant United States of America stipulate and
jointly request that the Court modify the Amended Pretrial Scheduling Order (ECF 24)
issued on January 23, 2018. Specifically, the parties request that the Court move the
hearing date on Defendant’s jurisdictional motion from April 20, 2015, to June 15, 2018,
with the Defendant’s jurisdictional motion to be filed on May 18, 2018.
Good cause exists for this request:


Counsel for Plaintiff Angela Jae Chun, Esq. is expecting her second child and
is scheduled to be induced on April 17, 2018, due to medical reasons. Ms.

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Chun’s maternity leave now begins on March 23, 2018.

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

jurisdictional motion, Plaintiff’s opposing papers are due on April 6, 2018.

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Based on the currently scheduled April 20, 2018, hearing date on Defendant’s

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Counsel for Plaintiff’s colleague who will be working on and opposing

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Defendant’s jurisdictional motion for Ms. Chun while she is on maternity

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leave is unavailable during the end of March/early April 2018 due to a pre-

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planned and pre-paid family vacation.

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

oppose Defendant’s jurisdictional motion in Ms. Chun’s absence.

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

June 15, 2018 is the first available hearing date on the Court’s calendar on
which both parties are available.

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There is no other attorney available at Counsel for Plaintiff’s firm that can

Based on the above, the parties stipulate and jointly request the Court modify the

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Amended Pretrial Order (ECF 24) to move the hearing date on Defendant’s jurisdictional

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motion from April 20, 2018, to June 15, 2018, with Defendant’s jurisdictional motion to be

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filed on May 18, 2018.

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Dated: March 22, 2018

CASEY GERRY SCHENK
FRANCAVILLA BLATT &
PENFIELD, LLP

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By:
/s/ Angela Jae Chun
Angela Jae Chun
Attorneys for Plaintiff
Gianfranco Ruffino

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McGREGOR W. SCOTT
United States Attorney

Dated: March 22, 2018

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By:

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/s/ Philip A. Scarborough

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Philip A. Scarborough
Assistant United States Attorney
Attorneys for Defendant
United States of America

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ORDER

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GOOD CAUSE APPEARING, the parties’ stipulation and joint request to modify the

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Amended Scheduling Order is APPROVED. Defendant shall file its jurisdictional motion

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on or before May 18, 2018, and the hearing on motion is moved from April 20, 2018 to June

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15, 2018 at 10:00 a.m., in Courtroom No. 3. Discovery is stayed as of March 23, 2018. The

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remainder of the Court’s scheduling order (ECF No. 24) remains in effect.

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DATED: April 3, 2018.

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UNITED STATES DISTRICT JUDGE

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