Lakes v. Bath & Body Works, LLC

Filing 195

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 11/24/202 0 CONTINUING the hearing on plaintiff's 178 Motion for Leave to Conduct Limited Discovery to 12/16/2020 at 10:00 AM in Courtroom 26 (AC) before Magistrate Judge Allison Claire.(Kastilahn, A)

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DANIEL L. STANNER
Admitted Pro Hac Vice
TABET DIVITO & ROTHSTEIN LLC
209 S. LaSalle Street, 7th Floor
Chicago, IL 60604
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff,
CRYSTAL LAKES

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DAVID S. OSTERMAN
Admitted Pro Hac Vice
GOLDBERG SEGALLA
301 Carnegie Center Drive, Suite 200
Princeton, NU 08540
Telephone: [phone] x5710
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant,
BATH & BODY WORKS, LLC

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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CRYSTAL LAKES, an individual,
Plaintiff,

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v.

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NO. 2:16-cv-02989-MCE-AC

BATH & BODY WORKS, LLC, a
Delaware limited liability company,

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Defendant.

STIPULATION AND [PROPOSED] ORDER
REQUESTING AN EXTENSION FOR
HEARING AND PLAINTIFF’S REPLY IN
SUPPORT OF HER MOTION FOR LEAVE TO
CONDUCT LIMITED DISCOVERY (Dkt. No.
178)

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Pursuant to Local Rules 143 and 144, it is hereby stipulated and agreed by and

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between Plaintiff Crystal Lakes (“Plaintiff”) and Defendant Bath & Body Works, LLC

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(“Defendant”), through their undersigned counsel, that parties request that the Court

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continue the hearing on Plaintiff’s Motion for Leave to Conduct Limited Discovery (Dkt.

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No. 178) (the “Motion”) to December 16, 2020 at 10:00 a.m.1 The grounds for this

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continuance are that despite Plaintiff’s diligence, due to several other matters that have

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The Motion has been submitted without oral argument pursuant to the Judge Claire’s order. (Dkt.
No. 184.)

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required Plaintiff’s counsel’s immediate attention, Plaintiff will be unable to file her reply

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in support of the Motion on or before the current November 25, 2020 deadline. (See

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Dkt. No. 190.) Defendant previously sought two continuances of the hearing date by

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stipulation to allow it to file its opposition to the Motion. (Dkt. Nos. 182 and 190.) The
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parties stipulate that the ends of justice will be served by this continuance so that

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Plaintiff’s counsel may have reasonable time necessary for effective preparation and

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filing of a proper reply brief in support of the Motion. The parties further stipulate that no

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party will suffer any prejudice if the requested continuance is granted. Accordingly, for

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these reasons and for good cause stated herein, by stipulation, the parties request that
the Court continue hearing on the Motion to December 16, 2020 to allow Plaintiff to file

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her reply brief in support of the Motion no later than December 9, 2020.
IT IS SO STIPULATED.
Dated: November 24, 2020

TABET DIVITO & ROTHSTEIN LLC

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By: /s/ Daniel L. Stanner
DANIEL L. STANNER
Attorneys for Plaintiff,
CRYSTAL LAKES

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Dated: November 24, 2020

CLAPP MORONY VUCINICH BEEMAN
SCHELEY

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By: /s/ Elizabeth D. Rhodes
ELIZABETH D. RHODES
Attorneys for Defendant,
BATH & BODY WORKS, LLC

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[PROPOSED] ORDER
Good cause appearing therefore, pursuant to the parties’ Amended Stipulation,
the Court hereby continues the hearing on Plaintiff’s Motion for Leave to Conduct

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Limited Discovery (Dkt. No. 178) to December 16, 2020 at 10:00 a.m. in Courtroom 26.
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All filing dates are to be calculated pursuant to that continued date.
IT IS SO ORDERED.
DATED: November 24, 2020

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