Avtenieva v. Randstad General Partner (US) LLC et al

Filing 19

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 11/27/17: The deadline for completion of discovery shall be extended to June 15, 2018.(Kaminski, H)

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SEYFARTH SHAW LLP
Lindsay S. Fitch (SBN 238227)
[e-mail]
400 Capitol Mall, Suite 2350
Sacramento, California 95814-4428
Telephone:
[phone]
Facsimile:
[phone]
SEYFARTH SHAW LLP
Sumithra R. Roberts (SBN 256078)
[e-mail]
2029 Century Park East, Suite 3500
Los Angeles, California 90067-3021
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
RANDSTAD GENERAL PARTNER (US),
LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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OLGA AVTENIEVA,

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Case No. 2:17-CV-00417-TLN-CKD

Plaintiff,

STIPULATION TO EXTEND
DISCOVERY CUTOFF; ORDER

v.
RANDSTAD GENERAL PARTNER, (US) LLC,
a Delaware Limited Liability Company, SHARI’S
BERRIES, INC., a California Corporation, and
Does 1 through 20, inclusive,

Judge Troy L. Nunley
Magistrate Judge Carolyn K. Delaney

Defendant.

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Plaintiff OLGA AVTENIEVA (“Plaintiff”) and Defendant RANDSTAD GENERAL

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PARTNER (US), LLC (“Defendant”), by and through their counsel, subject to the court’s

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approval, hereby stipulate as follows:

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1.

The First Amended Complaint in this action was filed on January 27, 2017.

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2.

On May 3, 2017, the Court issued its Pre-Trial Scheduling Order and set a

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discovery cut-off date of March 1, 2018, a dispositive motion deadline of September 6, 2018,

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STIPULATION TO EXTEND DISCOVERY CUT-OFF; ORDER

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and a trial date of February 4, 2019.
3.

Since May 3, 2017, the parties have engaged in written discovery and have

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scheduled several depositions including the depositions of Plaintiff, and Randstad employees

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Laurence Fouques and Emily Salerno for November and December 2017.

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4.

The parties also engaged in mediation through the Voluntary Dispute Resolution

Program on August 16, 2017, but were not able to resolve this matter.
5.

Due to the upcoming maternity leave of Defendant’s counsel Sumithra R.

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Roberts, Esq., and the schedule of Defendant’s counsel Lindsay L. Fitch, and the constraints on

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scheduling the depositions of at least five additional witnesses around the country, the parties

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wish to extend the discovery cutoff to June 15, 2018. Because this new cutoff falls three

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months before the dispositive motion deadline, the parties do not believe this extension will

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force a change in any other scheduled dates, including the trial date.

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NOW, THEREFORE, SUBJECT TO THE COURT’S APPROVAL, THE PARTIES AGREE

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AS FOLLOWS:

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1.

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The deadline for completion of discovery only shall be extended to June 15, 2018.

IT IS SO STIPULATED.
Dated: November 22, 2017

BRYANT WHITTEN, LLP

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/s/ Shelley Bryant
Shelley Bryant, Esq.
Attorneys for Plaintiff
OLGA AVTENIEVA

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Dated: November 22, 2017

SEYFARTH SHAW, LLP

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/s/ Lindsay S. Fitch
Lindsay S. Fitch, Esq.
Sumithra R. Roberts, Esq.
Attorneys for Defendant
RANDSTAD GENERAL PARTNER (US), LLC

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STIPULATION TO EXTEND DISCOVERY CUT-OFF; ORDER

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ORDER

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The undersigned has considered and approves the Stipulation to Extend the Discovery Cutoff to

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June 15, 2018.
IT IS SO ORDERED.

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DATED: November 27, 2017

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Troy L. Nunley
United States District Judge

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STIPULATION TO EXTEND DISCOVERY CUT-OFF; ORDER