Kyei v. Dragados USA, Inc. et al

Filing 10

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 11/28/18 EXTENDING the Completion of Discovery and hearing on any Dispositive Motions to 01/31/19. (Benson, A.)

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THE VELEZ LAW FIRM, PC
MARK VELEZ (SBN 163484)
3010 Lava Ridge Court, Suite 180
Roseville, CA 95661
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff
KOFI KYEI

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JACKSON LEWIS P.C.
JAMES T. JONES (SBN 167967)
400 Capitol Mall, Suite 1600
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendants
DRAGADOS USA, INC. and
LLOYD NEAL

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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KOFI KYEI, an individual,

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Plaintiff,

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Case No. 2:17-CV-01875-WBS-CKD
STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME TO
COMPLETE DISCOVERY AND
DISPOSITIVE MOTIONS

v.
DRAGADOS USA, INC., a Delaware
Corporation, LLOYD NEAL, an individual;
and DOES 1 through 100, inclusive.

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Defendants.

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Plaintiff Kofi Kyei (“Plaintiff”) and Defendants Dragados USA, Inc. and Lloyd Neal

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(“Defendants”) (collectively, “the Parties”), by and through their undersigned counsel, hereby

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stipulate and agree as follows:

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Stipulation and Proposed Order Extending Time to Complete Discovery and Dispositive Motions

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WHEREAS, counsel for Plaintiff, Mark Velez of The Velez Law Firm, PC, substituted
into this case on or about October 30, 2018;

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WHEREAS, the deposition of Plaintiff Kofi Kyei was postponed upon request from

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Plaintiff’s former attorney of record because Plaintiff resides out of state and Plaintiff’s former

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counsel wanted to attempt to resolve the matter through negotiation before incurring the expense

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of a deposition;
WHEREAS, counsel for Defendants agreed to the request of Plaintiff’s counsel, but the

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parties were not able to resolve the matter;
WHEREAS, Plaintiff’s new counsel of record needs additional time to complete

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necessary discovery and counsel for Defendants does not oppose such;

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THEREFORE, the Parties stipulate and agree, through their respective counsel, that

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should the Court so approve, the Parties shall complete all discovery and shall file any dispositive

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motions by not later than January 31, 2019.

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Dated: November 15, 2018

THE VELEZ LAW FIRM PC

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By: /s/ Mark Velez [as authorized on 11.15.18]
Mark Velez
Attorneys for Plaintiff
KOFI KYEI

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Dated: November 21, 2018

JACKSON LEWIS P.C.

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By: /s/ James T. Jones
James T. Jones
Attorneys for Defendants
DRAGADOS USA, INC. and LLOYD NEAL

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ORDER

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Based upon the foregoing stipulation of the Parties, and good cause appearing therefor,

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IT IS HEREBY ORDERED:

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The Parties shall complete all discovery and shall file any dispositive motions by not later

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than January 31, 2019.
Dat

Dated: November 28, 2018ed:

November 28, 2018

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Stipulation and Proposed Order Extending Time to Complete Discovery and Dispositive Motions