McGraw-Hill Global Education Holdings, LLC et al v. Stolyarchuk

Filing 25

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 8/3/2018 MODIFYING the 12 Pre Trial Scheduling order as follows: Designation of Expert Witnesses due by 10/31/2018; Discovery shall be completed by 1/7/2019; Dispositive Motions filed by 2/4/2019; Final Pretrial Conference set for 5/13/2019 at 01:30 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb; Jury Trial set for 7/16/2019 at 09:00 AM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Zignago, K.)

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NAOMI JANE GRAY (SBN 230171)
SHADES OF GRAY LAW GROUP, P.C.
100 Shoreline Highway, Suite 100B
Mill Valley, CA 94941
Telephone: [phone]
Facsimile: [phone]
[e-mail]

MICHAEL J. IOANNOU (SBN 95208)
[e-mail]
KEVIN W. ISAACSON (SBN 281067)
[e-mail]
CLARK A. WALDON (SBN 312696)
[e-mail]
ROPERS, MAJESKI, KOHN & BENTLEY
50 West San Fernando Street, Suite 1400
San Jose, CA 95113
Telephone:
[phone]
Facsimile:
[phone]

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SCOTT ZEBRAK
JEFFREY M. GOULD
OPPENHEIM + ZEBRAK, LLP
5225 Wisconsin Avenue NW, Suite 503
Washington, D.C. 20015
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Defendant
YAROSLAV STOLYARCHUK

Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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MCGRAW-HILL GLOBAL
EDUCATION HOLDINGS, LLC,
PEARSON EDUCATION, INC., and
CENGAGE LEARNING, INC.,

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Case No. 2:17-cv-01716-WBS-DB
JOINT STIPULATION AND CONSENT
SCHEDULING ORDER

Plaintiff,
v.
YAROSLAV STOLYARCHUK,
Defendant.

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WHEREAS, Plaintiffs filed their Complaint on August 17, 2017 and their First Amended
Complaint on April 12, 2018;
WHEREAS, on December 13, 2017, the Court entered a Status (Pretrial Scheduling)

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Order (ECF No. 10);
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JOINT STIPULATION AND CONSENT
SCHEDULING ORDER

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CASE NO. 17-cv-01716-WBS-DB

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WHEREAS, discovery commenced in December 2017;

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WHEREAS, the parties sought a previous modification of the Scheduling Order because

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discovery moved more slowly than anticipated (ECF No. 20), which modification the Court

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granted (ECF No. 22);
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WHEREAS, the parties necessitate additional time to conduct discovery in an efficient
manner;
WHEREAS, the parties also wish explore settlement discussions, without upcoming
litigation deadlines impeding the possibility of a settlement;
WHEREAS, in light of the above, the parties agree that additional time is necessary to
conclude settlement discussions, including, if the parties later agree, through Local Rule 271’s

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Voluntary Dispute Resolution Program; and
WHEREAS, this is the parties’ second request for an extension of any deadline in the
Court’s Pre-Trial Scheduling Order (ECF No. 10);
THE PARTIES JOINTLY CONSENT TO and request that the Court enter an order
modifying certain dates in the Order Modifying the Pre-Trial Scheduling Order (ECF No. 22), as
follows:

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Old Date

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Rule 26(a)(2) expert witness disclosures

August 31, 2018

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February 4, 2019

February 11, 2019

May 13, 2019

April 16, 2019

Trial

January 7, 2019

November 30, 2018

Final pre-trial conference

November 28, 2018

October 26, 2018

Deadline to file dispositive motions

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October 31, 2018

September 21, 2018

Rebuttal expert witness reports
Completion of discovery

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New Date

July 16, 2019*

* or at the Court’s earliest convenience thereafter.

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JOINT STIPULATION AND CONSENT
SCHEDULING ORDER

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CASE NO. 17-cv-01716-WBS-DB

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All other dates listed in the Pre-Trial Scheduling Order (ECF No. 10) shall remain in
place.

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Respectfully submitted,
Dated: August 2, 2018

SHADES OF GRAY LAW GROUP, P.C.
NAOMI JANE GRAY

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OPPENHEIM + ZEBRAK, LLP
SCOTT ZEBRAK
JEFFREY M. GOULD (pending pro hac vice)

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/s/ Jeffrey M. Gould
Attorneys for Plaintiffs

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ROPERS, MAJESKI, KOHN & BENTLEY
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/s/ Kevin Isaacsson
MICHAEL J. IOANNOU
KEVIN ISAACSON
CLARK A. WALDON

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Attorneys for Defendant
YAROSLAV STOLYARCHUK

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It is so ORDERED.

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Dated: August 3, 2018

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JOINT STIPULATION AND CONSENT
SCHEDULING ORDER

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CASE NO. 17-cv-01716-WBS-DB