Guina v. River Pines Public Utility District et al

Filing 19

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 06/27/19 MODIFYING the Scheduling Order dates as follows: Discovery Cut Off: 11/01/19; Expert Disclosure: 11/15/19; Rebuttal Experts: 12/30/19; Expert Discovery Cutoff: 02/13/20; Dispositive Motions: 04/10/20. (Benson, A.)

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STEVEN M. FINK (SBN 47789)
[e-mail]
JOHN KEVIN CROWLEY (SBN 88189)
[e-mail]
125 S. Market Street, Suite 1200
San Jose, CA 95113-2288
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
GREG GUINA
JACKSON LEWIS P.C.
MICHAEL J. CHRISTIAN (SBN 173727)
[e-mail]
ASHLEY L. EVANS (SBN 308727)
[e-mail]
400 Capitol Mall, Suite 1600
Sacramento, California 95814
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendants
RIVER PINES PUBLIC UTILITY DISTRICT,
CANDI BINGHAM and CATHY LANDGRAF

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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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GREG GUINA,
Plaintiff,

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Case No. 2:18-cv-00530-KJM-EFB
JOINT STIPULATION AND REQUEST
FOR CONTINUANCE OF CERTAIN
PRETRIAL DEADLINES AND ORDER

v.
RIVER PINES PUBLIC UTILITY DISTRICT;
CANDI BINGHAM, an individual; CATHY
LANDGRAF, an individual,

Complaint filed: March 12, 2018
Trial Date:
TBD

Defendants.

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Plaintiff GREG GUINA (“Plaintiff”) and Defendants RIVER PINES PUBLIC UTILITY

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DISTRICT (“Defendant RPPUD”), CANDI BINGHAM (“Defendant Bingham”), and CATHY

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LANDGRAF (“Defendant Landgraf”), (collectively referred to as “the Parties”), through counsel,
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JOINT STATUS REPORT

Case No. 2:18-cv-00530-KJM-EFB
Greg Guina v. River Pines Public Utility District, et al.

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hereby enter into the following Stipulation and request the Court to extend certain pretrial discovery

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deadlines, pursuant to the applicable Local Rules:

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1.

This is an action for alleged violations of civil rights, retaliation, hostile work

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environment and wrongful termination. The Parties have been engaged in extensive discovery

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including exchanging significant written discovery and conducting depositions of all the Parties.

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The completion of the discovery to date has been delayed by health issues suffered by Plaintiff’s

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counsel Steven Fink.

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2.

With the discovery completed to date, the Parties have agreed to participate in mediation

before retired Federal Judge Raul Ramirez. The Parties are in the process of selecting a date with
Judge Ramirez and expect mediation to occur within the next 60 days.

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3.

The Parties require additional discovery to be completed, including numerous

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depositions of third party witnesses, to adequately prepare if the matter should proceed to the filing

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of a dispositive motion and/or trial. The Parties ability to complete the mediation and the additional

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required discovery will be delayed due to a health issue with Defendant’s lead counsel Michael J.

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Christian and an anticipated surgical procedure.

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4.

In order to allow time to mediate the case and complete the necessary discovery, the

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Parties request that the discovery including discovery motion cut off dates and the expert disclosure

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cut off dates should be continued to a date in the future. The Parties hereby stipulate to the

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following new discovery dates and expert discovery and request the Court modify the scheduling

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order accordingly:

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Category
Discovery Cut Off
Expert Disclosure
Rebuttal Experts
Expert Discovery Cutoff
Dispositive Motions

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///

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Proposed Deadline
November 1, 2019
November 15, 2019
December 30, 2019
February 13, 2020
April 10, 2020

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Original Deadline
July 1, 2019
July 15, 2019
August 29, 2019
October 13, 2019
December 4, 2019

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JOINT STATUS REPORT

Case No. 2:18-cv-00530-KJM-EFB
Greg Guina v. River Pines Public Utility District, et al.

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5.

There have been no prior requests for extensions of time to change the case scheduling

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order (Docket number 15) and to extend time for completion of the alternative dispute resolution.

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Trial is currently not set.

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Respectfully submitted,

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Dated: June 21, 2019

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By: /s/ John K. Crowley [as auth. 6.21.19]
Steven M. Fink
John Kevin Crowley

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Attorneys for Plaintiff
GREG GUINA

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Dated: June 21, 2019

JACKSON LEWIS P.C.

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By:

/s/ Michael J. Christian
Michael J. Christian
Attorneys for Defendants
RIVER PINES PUBLIC UTILITY
DISTRICT, CANDI BINGHAM and
CATHY LANDGRAF

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ORDER

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IT IS SO ORDERED.
DATED: June 27, 2019.

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UNITED STATES DISTRICT JUDGE

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JOINT STATUS REPORT

Case No. 2:18-cv-00530-KJM-EFB
Greg Guina v. River Pines Public Utility District, et al.