Bess v. Adams & Associates, Inc.

Filing 31

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 3/24/2020 CONTINUING cutoff for non-expert discovery to 7/27/2020, expert witness disclosure to 8/7/2020, and the last day to hear dispositive motions to 1/7/2021. (Zignago, K.)

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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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JOHN H. ADAMS, JR., Bar No. 253341
LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
Telephone:
916.830.7200
[e-mail]
Attorneys for Defendant
ADAMS & ASSOCIATES, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Plaintiff,

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Case No.: 2:17-cv-00173-TLN-KJN

KEVIN BESS,

STIPULATION AND ORDER TO CONTINUE
THE PERIOD FOR DISCOVERY AND TO
CONTINUE EXPERT DISCLOSURE AND
DISPOSITIVE MOTION DEADLINES

v.
ADAMS & ASSOCIATES, INC., a Nevada
corporation; and DOES 1 to 25 inclusive,
Defendant.

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STIPULATION TO CONTINUE DISCOVERY CUTOFF

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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 from April 6, 2020, to July 27, 2020, as well as the expert disclosure deadline

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and last day to hear dispositive motions. This is the third request by the parties to extend discovery, as

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the initial order from the court contained a discovery cutoff of November 8, 2019. This is the second

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request of the Parties to continue other deadlines in this action. In support of this stipulation, the Parties

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offer the following:
1.

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The Parties were set to complete the outstanding depositions before the current discovery

cutoff but jointly decided to postpone further discovery due to concerns regarding travel and gathering in
light of the COVID-19 pandemic and the State of California’s Stay at Home order.
2.

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

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wish to continue the deadline for disclosure of expert witnesses and the last day to hear dispositive

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motions. The current expert disclosure deadline is January 9, 2020, and the current last day to hear

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dispositive motions is May 14, 2020. There is no trial currently date set in this action.
3.

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

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extension of the fact discovery cutoff from April 6, 2020, to July 27, 2020, would allow the Parties

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sufficient time to complete fact discovery once the current Stay at Home order is lifted. The Parties also

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believe that a continuance of the expert disclosure deadline from April 16, 2020, to August 7, 2020, and

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a continuance of the last day to hear dispositive motions from August 14, 2020, to December 29, 2020,

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would allow for completion of all discovery and the filing of dispositive motions, should such be

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determined to be necessary, without undue delay of 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 July 27, 2020; that the expert witness disclosure deadline be

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extended to August 7, 2020; and the last day to hear dispositive motions be continued to December 29,

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2020.

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STIPULATION TO CONTINUE DISCOVERY CUTOFF

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IT IS SO STIPULATED.
Dated: March 24, 2020

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By:_/s/ William L. Bowen (as authorized on 03.24.2020
WILLIAM L. BOWEN
BOWEN LAW FIRM
Attorney for Plaintiff,
KEVIN BESS

Dated: Mach 24,2020
By:

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_/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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ORDER

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IT IS HEREBY ORDERED that the cutoff for non-expert discovery is extended to July 27,
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2020; that the expert witness disclosure deadline is extended to August 7, 2020; and the last day to hear
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dispositive motions is continued to January 7, 2021.
DATED: March 24, 2020

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Troy L. Nunley
United States District Judge

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STIPULATION TO CONTINUE DISCOVERY CUTOFF