Hennessey v. Sierra Nevada Journeys

Filing 17

STIPULATION and ORDER signed by District Judge John A. Mendez on 8/22/2018 CONTINUING discovery completion deadline to 11/29/2018 and designation of expert witnesses to 10/26/2018. (Zignago, K.)

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DOWNEY BRAND LLP
CASSANDRA M. FERRANNINI (Bar No. 204277)
BRADLEY C. CARROLL (Bar No. 300658)
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Telephone:
916.444.1000
Facsimile:
916.444.2100
[e-mail]
[e-mail]
Attorneys for Defendant
SIERRA NEVADA JOURNEYS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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TIAMBRA HENNESSEY,

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DOWNEY BRAND LLP

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Plaintiff,

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Case No. 2:17-CV-02321-JAM-DB
JOINT STIPULATION AND ORDER
REGARDING DISCOVERY SCHEDULE

v.
SIERRA NEVADA JOURNEYS, A
NEVADA CORPORATION, AND DOES
1 THROUGH 100, INCLUSIVE,

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Complaint Removed:

November 6, 2017

Defendants.

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STIPULATION

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Plaintiff TIAMBRA HENNESSEY (“Plaintiff”) and Defendant SIERRA NEVADA

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JOURNEYS (“Defendant”) (collectively, “Parties”), by and through their respective attorneys of

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records, stipulate and agree as follows:

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1.

2018, by the Court’s scheduling order.

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That the deadline to complete all discovery in this action was set at October 26,

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That the Parties wish to mediate their dispute in hopes of reaching a settlement of

this action.

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3.

That the Parties have agreed to attend mediation on October 24, 2018.

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4.

That the Parties wish to avoid the continued expense of discovery, including

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1529023.1

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY SCHEDULE

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depositions and expert discovery, pending their mediation.

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accommodate their mediation.

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That the Parties wish to extend the deadline to complete discovery to

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That the deadline for completing discovery in this action should be moved to

November 29, 2018.

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That the deadline for disclosure of expert witnesses should be moved to October

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26, 2018, and the supplemental disclosure and disclosure of any rebuttal experts should be moved

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to November 9, 2018.

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IT IS SO STIPULATED.

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DATED: August 22, 2018

DOWNEY BRAND LLP

DOWNEY BRAND LLP

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By:

/s/ Bradley C. Carroll
CASSANDRA M. FERRANNINI
BRADLEY C. CARROLL
Attorney for Defendant
SIERRA NEVADA JOURNEYS

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DATED: August 22, 2018

OTKUPMAN LAW FIRM, ALC

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By: /s/ Roman Otkupman (as authorized on 8/22/18)
ROMAN OTKUPMAN
Attorney for Plaintiff
TIAMBRA HENNESSEY

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1529023.1

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY SCHEDULE

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ORDER

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GOOD CAUSE APPEARING, it is hereby ORDERED that:

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1.

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The deadline for Plaintiff and Defendant to completed discovery in this matter

shall be moved from October 26, 2018, to November 29, 2018.

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2.

The deadline for Plaintiff and Defendant to disclose expert witnesses shall be

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moved to October 26, 2018, and the deadline for supplemental disclosure and disclosure of any

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rebuttal experts shall be moved to November 9, 2018

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IT IS SO ORDERED.
DATED: 8/22/2018

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/s/ John A. Mendez___________________

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United States District Court Judge

DOWNEY BRAND LLP

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1529023.1

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY SCHEDULE