Bess v. Adams & Associates, Inc.

Filing 29

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 1/6/20 ORDERING that the cutoff for non-expert discovery is extended to April 6, 2020; the expert witness disclosure deadline is extended to April 16, 2020; and the last day to hear dispositive motions is continued to August 20, 2020. (Kaminski, H)

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WILLIAM L. BOWEN, SBN. 229938
BOWEN LAW FIRM
2540 Douglas Blvd., Suite 200
Roseville, CA 95661
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff,
KEVIN BESS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KEVIN BESS,
Plaintiff,

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v.

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ADAMS & ASSOCIATES, INC., a Nevada

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corporation; and DOES 1 to 25 inclusive,
Defendant.

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Case No.: 2:17-cv-00173-TLN-KJN
STIPULATION AND ORDER TO CONTINUE
THE PERIOD FOR DISCOVERY AND TO
CONTINUE EXPERT DISCLOSURE AND
DISPOSITIVE MOTION DEADLINES

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Plaintiff Kevin Bess (“Plaintiff”) and Defendant Adams & Associates, Inc. (“Defendant”)

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(collectively “Parties”), by and through their respective counsel of record, hereby stipulate to extend the

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non-expert discovery cutoff by 90 days, from January 7, 2020 to April 6, 2020, as well as the expert

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disclosure deadline and last day to hear dispositive motions. This is a second request by the parties to

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extend discovery, as the initial order from the court contained a discovery cutoff of November 8, 2019.

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This is the first request of the Parties to continue other deadlines in this action. In support of this

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stipulation, the Parties offer the following:

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1.

The Parties believe that the current fact discovery cutoff does not allow enough time to

complete the discovery that the Parties anticipate they will need.

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STIPULATION AND ORDER TO CONTINUE DISCOVERY CUTOFF

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2.

The deposition of Plaintiff Bess has been partially completed and by agreement of the

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Parties will be completed at a date to be agreed upon. Upon completion of Plaintiff’s deposition, the

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Parties will schedule the deposition of Defendant’s Person Most Knowledgeable.

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3.

The Parties believe they require a limited extension of time to complete discovery and

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depositions and, out of an abundance of caution, wish to continue the deadline for disclosure of expert

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witnesses and the last day to hear dispositive motions. The current expert disclosure deadline is January 9,

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2020, and the current last day to hear dispositive motions is May 14, 2020. There is no trial currently date

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set in this action.

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4.

Having reviewed the respective schedules of counsel, the Parties believe that an

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extension of the fact discovery cutoff from January 7, 2020, to April 6, 2020, would allow the Parties

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sufficient time to complete fact discovery. The Parties also believe that a continuance of the expert

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disclosure deadline from January 9, 2020, to April 16, 2020, and a continuance of the last day to hear

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dispositive motions from May 14, 2020, to August 14, 2020, would allow for completion of all discovery

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and the filing of dispositive motions, should such be determined to be necessary, without undue delay of

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this matter.

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THEREFORE, the Parties stipulate and agree, subject to approval by the Court, that the cutoff

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for non-expert discovery be extended to April 6, 2020; that the expert witness disclosure deadline be

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extended to April 16, 2020; and the last day to hear dispositive motions be continued to August 14, 2020.

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IT IS SO STIPULATED.
Dated: January 3, 2020
By:

_/s/ William L. Bowen_______________
WILLIAM L. BOWEN
BOWEN LAW FIRM
Attorney for Plaintiff,
KEVIN BESS

By:

_/s/ John H. Adams, Jr._______________
MICHAEL G. PEDHIRNEY
JOHN H. ADAMS, JR.
LITTLER MENDELSON, P.C.
Attorney for Defendant,
ADAMS & ASSOCIATES, INC.

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Dated: January 3, 2020

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STIPULATION AND ORDER TO CONTINUE DISCOVERY CUTOFF

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ORDER

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IT IS HEREBY ORDERED that the cutoff for non-expert discovery is extended to April 6,
2020; the expert witness disclosure deadline is extended to April 16, 2020; and the last day to hear
dispositive motions is continued to August 20, 2020.

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Dated: January 6, 2020
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Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER TO CONTINUE DISCOVERY CUTOFF