Stonecypher v. Iasco Flight Training, Inc.

Filing 73

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 1/5/21 ORDERING that Second Supplemental Pre-trial Scheduling Order shall be modified to allow all remaining fact discovery, with the exception of expert discovery, to be completed no later than February 9, 2021. All other dates set forth in the Second Supplemental Pre-trial Scheduling Order remain unchanged. (Kaminski, H)

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Rob Hennig (SBN 174646)
[e-mail]
Brandon Ruiz (SBN 264603)
[e-mail]
Dat Tommy Phan (SBN 316813)
[e-mail]
HENNIG RUIZ & SINGH, P.C.
3600 Wilshire Blvd., Suite 1908
Los Angeles, CA 90010
Telephone: [phone]
Fax: [phone]

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Attorneys for Plaintiff MATTHEW STONECYPHER

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Michael D. Bruno (SBN 166805)
Joseph P. Breen (SBN 124330)
GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant IASCO FLIGHT TRAINING, INC.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MATTHEW STONECYPHER, an
individual,
Plaintiff,

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v.
IASCO FLIGHT TRAINING INC., a
California corporation,

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CASE NO. 2:17-cv-02409-MCE-JDP
JOINT STIPULATION FOR FURTHER
LIMITED EXTENSION OF DISCOVERY
DEADLINE; ORDER THEREON
Judge: Hon. Morrison C. England, Jr.
Courtroom: 7
Mag. Judge: Hon. Jeremy D. Peterson
Courtroom: 8

Defendant.
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JOINT STIPULATION FOR FURTHER LIMITED EXTENSION OF DISCOVERY DEADLINE; ORDER THEREON

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IT IS HEREBY STIPULATED by and between the Parties to Matthew

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Stonecypher v. IASCO Flight Training, Inc. et al., (“the Parties”) by and through their

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respective counsel of record, to seek leave of court to further modify the Second

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Supplemental Pre-trial Scheduling Order issued on June 1, 2020, [Document 40] (“the

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Scheduling Order”) and briefly extend the existing discovery deadline of January 11,

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2021, until February 9, 2021, based on the showing of good cause as follows:

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WHEREAS, the Second Supplemental Pre-trial Scheduling Order ordered that all

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fact discovery, with the exception of expert discovery, shall be completed no later than

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November 16, 2020;

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WHEREAS, the Court issued an Order on November 3, 2020, Document No. 60,

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and granted the Parties an extension until January 11, 2021, to complete fact discovery,

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with the exception of expert discovery;

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WHEREAS, the Parties seek to complete their fact discovery and resolve certain

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outstanding discovery issues that are now pending before Magistrate Judge Jeremy D.

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Peterson pursuant to the Court’s orders issued on November 25, 2020, Document No.

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65, and December 8, 2020, Document No. 67, respectively;

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WHEREAS, a limited extension of the deadline beyond January 11, 2021, will

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allow the Parties to resolve the outstanding discovery issues including the production of

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certain documents by January 6, 2021, and the scheduling and completion of

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depositions as agreed by the Parties concerning such documents; and

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WHEREAS, the Parties anticipate an extension granted until February 9, 2021,

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will allow sufficient time for the Parties to resolve the outstanding discovery issues

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including the document production and completion of depositions referenced above, the

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Parties respectfully request that the Court grant leave to modify the Scheduling Order as

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stated below:

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JOINT STIPULATION FOR FURTHER LIMITED EXTENSION OF DISCOVERY DEADLINE; ORDER THEREON

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IT IS SO STIPULATED. Respectfully submitted,

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HENNIG RUIZ & SINGH, P.C.

Dated: December 16, 2020

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By:

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_/s/ Rob Henning______________________
Rob Hennig
Brandon Ruiz
Dat Tommy Phan
Attorneys for Plaintiff
MATTHEW STONECYPHER

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GORDON REES SCULLY MANSUKHANI, LLP

Dated: December 16, 2020

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By:

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___/s/ Joseph Breen____________________
Joseph Breen
Attorneys for Defendant
IASCO FLIGHT TRAINING, INC.

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ORDER

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In accordance with the foregoing stipulation, and good cause appearing, the

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Second Supplemental Pre-trial Scheduling Order shall be modified to allow all remaining

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fact discovery, with the exception of expert discovery, to be completed no later than

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February 9, 2020. All other dates set forth in the Second Supplemental Pre-trial

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Scheduling Order remain unchanged.

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IT IS SO ORDERED.
Dated: January 5, 2021

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JOINT STIPULATION FOR FURTHER LIMITED EXTENSION OF DISCOVERY DEADLINE; ORDER THEREON

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JOINT STIPULATION FOR FURTHER LIMITED EXTENSION OF DISCOVERY DEADLINE; ORDER THEREON