Mejia v. Farmland Mutual Insurance Company et al

Filing 25

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 7/16/2018 ORDERING that the Parties shall meet and confer and submit new proposed deadlines for discovery, expert witness disclosures, and certification motion filing within 30 days after Defendants file an Answer. The Court's 6 Pretrial Scheduling Order shall remain in effect in all other respects. (Zignago, K.)

1
2
3
4
5
6
7

Galen T. Shimoda (Cal. State Bar No. 226752)
Justin P. Rodriguez (Cal. State Bar No. 278275)
Shimoda Law Corp.
9401 East Stockton Blvd., Suite 200
Elk Grove, CA 95624
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff SCARLETTE MEJIA
on behalf of herself and similarly situated employees

8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11
12
13
14
15
16
17
18
19
20
21

SCARLETTE MEJIA, as an individual and on )
)
behalf of all others similarly situated,
)
)
Plaintiffs,
)
)
)
vs.
)
)
FARMLAND MUTUAL INSURANCE
)
COMPANY, an Iowa corporation;
)
FARMLAND MUTUAL INSURANCE CO, )
an unincorporated association; NATIONWIDE )
)
MUTUAL INSURANCE COMPANY, an
)
Ohio corporation; and DOES 1 to 100,
)
inclusive,
)
)
)
)
Defendants.
)

Case No. 2:17-CV-00570-TLN-KJN
CLASS ACTION
STIPULATION & ORDER REGARDING
AMENDING PRETRIAL SCHEDULING
ORDER

22
23

This Stipulation and proposed Order is entered into between Plaintiff SCARLETTE MEJIA

24

(“Plaintiff”) and Defendants FARMLAND MUTUAL INSURANCE COMPANY, which was sued by

25

its correct name and also as FARMLAND MUTUAL INSURANCE CO, and NATIONWIDE

26

MUTUAL INSURANCE COMPANY (Hereinafter referred to as “Defendants”) (Plaintiff and

27

Defendants all collectively, the “Parties”), by and through their counsel of record, as follows:

28
STIP & ORDER RE SCHEDULING

Case No.: 2:17-at-00282

1

WHEREAS the Court issued a Pretrial Scheduling Order on May 19, 2017 [Dkt. No. 6] setting

1
2

certain deadlines;
WHEREAS Defendants filed a Motion to Dismiss and Strike Plaintiff’s Class Allegations on

3
4

June 29, 2017;
WHEREAS the Court issued an Order on August 17, 2017 [Dkt. No. 22] modifying the Pretrial

5
6

Scheduling Order to vacate the discovery deadline, expert witness disclosure deadline, and filing

7

deadline for class certification;
WHEREAS the Court’s August 17, 2017 Order also stated the parties would propose new

8
9

deadlines within fourteen (14) days of the Court denying Defendants’ Motion;
WHEREAS on June 26, 2018 the Court granted in part and denied in part Defendants’ Motion

10
11

and gave Plaintiff thirty (30) days to file a Second Amended Complaint [Dkt. 23];
WHEREAS the Parties believe it will help case management discussions and clarify the expected

12
13

deadlines for discovery and certification for purposes of submitting a modified scheduling order, if the

14

requirement for submission takes place after an operative Complaint and Answer are filed with the

15

Court;

16
17
18

IT IS HEREBY STIPULATED AND AGREED, by and between the Parties, subject to the
approval of the Court, as follows:
1.

The Parties shall meet and confer and submit new proposed deadlines for discovery,

19

expert witness disclosures, and certification motion filing within 30 days after Defendants file an

20

Answer;

21
22

2.

The Court’s May 19, 2017 Pretrial Scheduling Order [Dkt. No. 6] shall remain in effect

in all other respects.
LITTLER MENDELSON, P.C.

23
24

DATED: July 9, 2017

25
26

By:

/s/ Barbara A. Blackburn
Barbara A. Blackburn
Britney N. Torres
(As authorized on 7/9/18)
Attorneys for Defendants

27
28
STIP & ORDER RE SCHEDULING

Case No.: 2:17-at-00282

2

SHIMODA LAW CORP.

1
2

DATED: July 9, 2017

3
4
5
6
7

The COURT, having considered the above stipulation, HEREBY ORDERS that:
1.

12

The Parties shall meet and confer and submit new proposed deadlines for discovery,
expert witness disclosures, and certification motion filing within 30 days after Defendants

9

11

/s/ Justin P. Rodriguez
Galen T. Shimoda
Justin P. Rodriguez
Counsel for Plaintiff
ORDER

8

10

By:

file an Answer;
2.

The Court’s May 19, 2017 Pretrial Scheduling Order [Dkt. No. 6] shall remain in effect
in all other respects.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

13
14
15

Dated: July 16, 2018

16
17
18

Troy L. Nunley
United States District Judge

19
20
21
22
23
24
25
26
27
28
STIP & ORDER RE SCHEDULING

Case No.: 2:17-at-00282

3