Singh et al v. Lowe's Home Centers, LLC

Filing 36

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 9/10/19 MODIFYING the 32 Pretrial Scheduling Order as follows: Initial Expert Witness Disclosures due by 11/1/19. Non-Expert/Expert Discovery Cut-Off is 12/2/19. Rebuttal Expert Witness Disclosures due by 11/15/19. Discovery Motions cut-off is 12/2/19. (Coll, A)

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STEPHANIE FORMAN, ESQ.; STATE BAR NO.: 195757
DIANA M. RIVERA, ESQ.; STATE BAR NO.: 222025
THARPE & HOWELL, LLP
15250 Ventura Blvd., Ninth Floor
Sherman Oaks, California 91403
[phone]; [phone] fax
E-Mail: [e-mail]
E-Mail: [e-mail]
Attorneys for Defendant,
LOWE’S HOME CENTERS, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

THARPE & HOWELL, LLP
15250 Ventura Boulevard, Ninth Floor
Sherman Oaks, California 91403-3221

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PAUL SINGH and ANDREA SINGH,

[Sutter County Superior Court; Case No.:
CVCS17-0001866]

Plaintiff,

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v.

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LOWE’S HOME CENTERS, LLC,
and DOES 1 to 50, Inclusive,

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Defendants.

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Case No. 2:18-cv-00445-WBS-AC

[PROPOSED] ORDER ON JOINT
STIPULATION FOR ORDER TO
MODIFY COURT’S AUGUST 29, 2018
PRETRIAL SCHEDULING ORDER

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[PROPOSED] ORDER

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The Court, having read and considered the Joint Stipulation for an Order to

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Modify the Court’s August 29, 2018 Pretrial Scheduling Order, and good cause

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appearing therefore, rules as follows:

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IT IS HEREBY ORDERED THAT the Initial Expert Witness Disclosures date
is now November 1, 2019.

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IT IS HEREBY ORDERED THAT the Rebuttal Expert Witness Disclosures
date is now November 15, 2019.

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IT IS HEREBY ORDERED THAT the Non-Expert/Expert Discovery Cut-Off

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date is now December 2, 2019.

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///
-1[PROPOSED] ORDER ON JOINT STIPULATION
SINGH V. LOWE’S HOME CENTERS, LLC
Case No.: 2:18-cv-00445-WBS-AC

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IT IS HEREBY ORDERED THAT the Discovery Motion Cut-Off date is now
December 2, 2019.
IT IS FURTHER ORDERED THAT all other dates and deadlines are to remain
unchanged.

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IT IS SO ORDERED.

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Dated: September 10, 2019

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THARPE & HOWELL, LLP
15250 Ventura Boulevard, Ninth Floor
Sherman Oaks, California 91403-3221

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-2[PROPOSED] ORDER ON JOINT STIPULATION
SINGH V. LOWE’S HOME CENTERS, LLC
Case No.: 2:18-cv-00445-WBS-AC

PROOF OF SERVICE

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STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

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1. At the time of service, I was at least 18 years of age and not a party to this legal
action.
2. My business address is 15250 Ventura Boulevard, Ninth Floor, Sherman Oaks,
CA 91403.

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3. I served copies of the following documents (specify the exact title of each
document served):
[PROPOSED] ORDER ON JOINT STIPULATION FOR ORDER TO
MODIFY COURT’S AUGUST 29, 2018 PRETRIAL SCHEDULING
ORDER

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THARPE & HOWELL, LLP
15250 Ventura Boulevard, Ninth Floor
Sherman Oaks, California 91403-3221

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4. I served the documents listed above in item 3 on the following persons at the
addresses listed:
Attorneys for Plaintiffs,
Edward Misleh, Esq.
PAUL SINGH and ANDREA SINGH
LAW OFFICES OF EDWARD
MISLEH
615 10th Street
Sacramento, CA 95814
[phone]; [phone] – Fax
5. a.

By personal service. I personally delivered the documents on the date
shown below to the persons at the addresses listed above in item 4. (1)
For a party represented by an attorney, delivery was made to the
attorney or at the attorney's office by leaving the documents in an
envelope or package clearly labeled to identify the attorney being served
with a receptionist or an individual in charge of the office. (2) For a
party delivery was made to the party or by leaving the documents at the
party's residence between the hours of eight in the morning and six in
the evening with some person not less than 18 years of age.

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b.

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By United States mail. I enclosed the documents in a sealed envelope
or package addressed to the persons at the addresses in item 4 and
(specify one):

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(1)

deposited the sealed envelope with the United States Postal
Service, with the postage fully prepaid on the date shown
below, or

(2) X

placed the envelope for collection and mailing on the date
shown below, following our ordinary business practices. I am
readily familiar with this business's practice for collecting and
processing correspondence for mailing. On the same day that
correspondence is placed for collection and mailing, it is
deposited in the ordinary course of business with the United
States Postal Service, in a sealed envelope with postage fully
prepaid.

x

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-3[PROPOSED] ORDER ON JOINT STIPULATION
SINGH V. LOWE’S HOME CENTERS, LLC
Case No.: 2:18-cv-00445-WBS-AC

I am a resident or employed in the county where the mailing occurred.
The envelope or package was placed in the mail at Sherman Oaks,
California.

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c.

By overnight delivery. I enclosed the documents on the date shown
below in an envelope or package provided by an overnight delivery
carrier and addressed to the person at the addresses in item 4. I placed the
envelope or package for collection and overnight delivery at an office or a
regularly utilized drop box of the overnight delivery carrier.

d.

By messenger service. I served the documents on the date shown
below by placing them in an envelope or package addressed to the
person on the addresses listed in item 4 and providing them to a
professional messenger service for service.

e.

By fax transmission. Based on an agreement of the parties to accept
service by fax transmission, I faxed the documents on the date shown
below to the fax numbers of the persons listed in item 4. No error was
reported by the fax machine that I used. A copy of the fax transmission,
which I printed out, is attached to my file copy.

f.

By e-mail or electronic transmission. Based on an agreement of the
parties to accept service by e-mail or electronic transmission, I caused
the documents to be sent on the date shown below to the e-mail addresses
of the persons listed in item 4. I did not receive within a reasonable time
after the transmission any electronic message or other indication that the
transmission was unsuccessful.

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THARPE & HOWELL, LLP
15250 Ventura Boulevard, Ninth Floor
Sherman Oaks, California 91403-3221

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6. I served the documents by the means described in item 5 on (date): see below

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I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.

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8/28/19
DATE

Belinda A. Porras
(TYPE OR PRINT NAME)

/s/ Belinda A. Porras
(SIGNATURE OF DECLARANT)

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I:\29000-000\29074\Pleadings\Federal\Proposed Order Stip Re Expert Disclosures.docx

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-4[PROPOSED] ORDER ON JOINT STIPULATION
SINGH V. LOWE’S HOME CENTERS, LLC
Case No.: 2:18-cv-00445-WBS-AC