Bess v. Adams & Associates, Inc.

Filing 33

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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1 2 3 4 5 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 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 KEVIN BESS, 12 Plaintiff, 13 v. 14 ADAMS & ASSOCIATES, INC., a Nevada 15 corporation; and DOES 1 to 25 inclusive, 16 Defendant. 17 18 19 Case No.: 2:17-cv-00173-TLN-KJN ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) JOINT STIPULATION AND ORDER TO CONTINUE THE PERIOD FOR DISCOVERY BEYOND THE INITIAL CUTOFF Plaintiff Kevin Bess (“Plaintiff”) and Defendant Adams & Associates, Inc. (“Defendant”) 20 (collectively “Parties”), by and through their respective counsel of record, hereby stipulate to extend the 21 non-expert discovery cutoff by 90 days, from July 27, 2020 to October 26, 2020. The parties further 22 request that the expert witness disclosure deadline be extended from August 7, 2020 to November 6, 2020 23 and that the last day to hear dispositive motions is continued to April 8, 2021. The parties have made 24 prior requests to continue discovery based on issues with the availability of witnesses and other issues. 25 This request is made in light of the Covid-19 pandemic and technical issues which arose with attempts by 26 the parties to complete the depositions of the parties. All Parties hereby confirm that they have met and 27 conferred through-out the discovery process and continue to work to complete discovery in a timely and 28 reasonably safe manner. In support of this stipulation, the parties offer the following: 1 JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF 1 2 3 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. 2. The Parties have met and conferred in good faith to complete fact discovery before the 4 current pending deadline of July 27, 2020. However, the Covid-19 pandemic and technical issues with 5 setting remote depositions have created a series of delays beyond the control of the parties or their 6 counsel. 7 3. The Parties recognize that they have previously requested an extension of discovery 8 deadlines in this matter, but they believe that a further extension is necessary to complete discovery in a 9 manner that believe they require a limited extension of time to complete discovery and depositions 10 11 without affecting any other deadline established by the Court. 4. Having reviewed the respective schedules of counsel, the Parties believe that an 12 extension of the fact discovery cutoff by 90 days would allow the parties sufficient time to complete fact 13 discovery without prejudicing the rights of either party. 14 THEREFORE, the Parties stipulate and agree, subject to approval by the Court, that the cutoff 15 for non-expert discovery be extended by 90 days, making the new deadline October 26, 2020. The parties 16 further request that the deadline for expert witness disclosure be extended to November 6, 2020 and the 17 last day to hear dispositive motions is continued to April 8, 2021 18 19 IT IS SO STIPULATED. Dated: July 20, 2020 20 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. 21 22 23 Dated: July 20, 2020 24 25 26 27 28 2 JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF ORDER 1 2 IT IS HEREBY ORDERED that the cutoff for non-expert discovery is extended to October 26, 3 2020; the expert witness disclosure deadline is extended to November 6, 2020; and the last day to hear 4 dispositive motions is continued to April 15, 2021. 5 Dated: July 24, 2020 6 7 8 Troy L. Nunley United States District Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF

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