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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1 2 3 4 5 6 7 8 9 10 SEYFARTH SHAW LLP Lindsay S. Fitch (SBN 238227) lfitch@seyfarth.com 400 Capitol Mall, Suite 2350 Sacramento, California 95814-4428 Telephone: (916) 448-0159 Facsimile: (916) 558-4839 SEYFARTH SHAW LLP Sumithra R. Roberts (SBN 256078) sroberts@seyfarth.com 2029 Century Park East, Suite 3500 Los Angeles, California 90067-3021 Telephone: (310) 277-7200 Facsimile: (310) 201-5219 Attorneys for Defendant RANDSTAD GENERAL PARTNER (US), LLC 11 12 UNITED STATES DISTRICT COURT 13 EASTERN DISTRICT OF CALIFORNIA 14 15 OLGA AVTENIEVA, 16 17 18 19 20 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. 21 22 Plaintiff OLGA AVTENIEVA (“Plaintiff”) and Defendant RANDSTAD GENERAL 23 PARTNER (US), LLC (“Defendant”), by and through their counsel, subject to the court’s 24 approval, hereby stipulate as follows: 25 1. The First Amended Complaint in this action was filed on January 27, 2017. 26 2. On May 3, 2017, the Court issued its Pre-Trial Scheduling Order and set a 27 discovery cut-off date of March 1, 2018, a dispositive motion deadline of September 6, 2018, 28 STIPULATION TO EXTEND DISCOVERY CUT-OFF; ORDER 1 2 and a trial date of February 4, 2019. 3. Since May 3, 2017, the parties have engaged in written discovery and have 3 scheduled several depositions including the depositions of Plaintiff, and Randstad employees 4 Laurence Fouques and Emily Salerno for November and December 2017. 5 6 7 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. 8 Roberts, Esq., and the schedule of Defendant’s counsel Lindsay L. Fitch, and the constraints on 9 scheduling the depositions of at least five additional witnesses around the country, the parties 10 wish to extend the discovery cutoff to June 15, 2018. Because this new cutoff falls three 11 months before the dispositive motion deadline, the parties do not believe this extension will 12 force a change in any other scheduled dates, including the trial date. 13 NOW, THEREFORE, SUBJECT TO THE COURT’S APPROVAL, THE PARTIES AGREE 14 AS FOLLOWS: 15 1. 16 17 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 18 /s/ Shelley Bryant Shelley Bryant, Esq. Attorneys for Plaintiff OLGA AVTENIEVA 19 20 21 22 Dated: November 22, 2017 SEYFARTH SHAW, LLP 23 24 25 26 27 /s/ Lindsay S. Fitch Lindsay S. Fitch, Esq. Sumithra R. Roberts, Esq. Attorneys for Defendant RANDSTAD GENERAL PARTNER (US), LLC 28 2 STIPULATION TO EXTEND DISCOVERY CUT-OFF; ORDER 1 ORDER 2 The undersigned has considered and approves the Stipulation to Extend the Discovery Cutoff to 3 4 June 15, 2018. IT IS SO ORDERED. 5 DATED: November 27, 2017 6 Troy L. Nunley United States District Judge 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION TO EXTEND DISCOVERY CUT-OFF; ORDER

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