Bess v. Adams & Associates, Inc.
Filing
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STIPULATION and ORDER signed by District Judge Troy L. Nunley on 7/24/2020 EXTENDING the cutoff deadlines as follows: The cutoff for non-expert discovery is EXTENDED to 10/26/2020. The expert witness disclosure deadline is EXTENDED to 11/6/2020; and the last day to hear dispositive Motions is CONTINUED to 4/15/2021. (Mena-Sanchez, L)
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WILLIAM L. BOWEN, SBN. 229938
BOWEN LAW FIRM
2540 Douglas Blvd., Suite 200
Roseville, CA 95661
Tel: (916) 742-2220
Fax: (916) 288-9858
wlb@bowenlegal.com
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,
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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,
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Defendant.
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Case No.: 2:17-cv-00173-TLN-KJN
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JOINT STIPULATION AND ORDER TO
CONTINUE THE PERIOD FOR DISCOVERY
BEYOND THE INITIAL CUTOFF
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 July 27, 2020 to October 26, 2020. The parties further
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request that the expert witness disclosure deadline be extended from August 7, 2020 to November 6, 2020
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and that the last day to hear dispositive motions is continued to April 8, 2021. The parties have made
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prior requests to continue discovery based on issues with the availability of witnesses and other issues.
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This request is made in light of the Covid-19 pandemic and technical issues which arose with attempts by
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the parties to complete the depositions of the parties. All Parties hereby confirm that they have met and
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conferred through-out the discovery process and continue to work to complete discovery in a timely and
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reasonably safe manner. In support of this stipulation, the parties offer the following:
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JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF
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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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The Parties have met and conferred in good faith to complete fact discovery before the
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current pending deadline of July 27, 2020. However, the Covid-19 pandemic and technical issues with
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setting remote depositions have created a series of delays beyond the control of the parties or their
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counsel.
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3.
The Parties recognize that they have previously requested an extension of discovery
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deadlines in this matter, but they believe that a further extension is necessary to complete discovery in a
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manner that believe they require a limited extension of time to complete discovery and depositions
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without affecting any other deadline established by the Court.
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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 by 90 days would allow the parties sufficient time to complete fact
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discovery without prejudicing the rights of either party.
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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 by 90 days, making the new deadline October 26, 2020. The parties
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further request that the deadline for expert witness disclosure be extended to November 6, 2020 and the
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last day to hear dispositive motions is continued to April 8, 2021
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IT IS SO STIPULATED.
Dated: July 20, 2020
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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: July 20, 2020
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JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF
ORDER
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IT IS HEREBY ORDERED that the cutoff for non-expert discovery is extended to October 26,
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2020; the expert witness disclosure deadline is extended to November 6, 2020; and the last day to hear
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dispositive motions is continued to April 15, 2021.
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Dated: July 24, 2020
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Troy L. Nunley
United States District Judge
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JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF
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