Ward-Peterson et al v. J.C. Penney Corporation, Inc., et al.,

Filing 16

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 3/30/2020 CONTINUING mediation and discovery deadlines to the following: Mediation to be completed by 10/17/2020; Discovery shall be completed by 6/3/2020; Disclosure of Expert Witnesses due by 7/2/2020; Disclosed expert witnesses of rebuttal due by 7/20/2020; Expert discovery to be completed by 8/20/2020; Hearing on Dispositive Motions by 10/16/2020. (Zignago, K.)

1 JOSEPH A. WELCH, SB# 119312
LAW OFFICES OF JOSEPH A. WELCH
2 E-Mail: [e-mail]
828 University Avenue
3 Sacramento, California 95825
Telephone: [phone]
4 Facsimile: 916.920.5505
5 Attorneys for Plaintiffs
KIMBERLY WARD-PETERSON and NOEL
6 PETERSON
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

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11 KIMBERLY WARD-PETERSON and NOEL
PETERSON,
12
Plaintiffs,
13
v.
14
J.C. PENNEY CORPORATION, INC., J.C.
15 PENNEY COMPANY, INC. and DOES 1
through 10, inclusive,
16
Defendants.
17
18

Case No. 2:18-cv-00567-KJM-DB
STIPULATION AND ORDER TO
CONTINUE DEADLINE TO COMPLETE
MEDIATION AND DISCOVERY
DEADLINES

THE PARTIES, BY AND THROUGH THEIR RESPECTIVE ATTORNEYS OF

19 RECORD, AGREE AND STIPULATE AS FOLLOWS:
20

The Court scheduled a mediation completion deadline of June 19, 2020. Due to the

21 transfer of handling attorneys, unavailability because of trial, and other scheduling issues, the
22 parties are unable to complete mediation and necessary depositions prior to the currently
23 scheduled deadlines. Additionally, the parties agree that there are additional depositions that must
24 be taken prior to mediating the case. Also, Plaintiffs’ attorney is scheduled for a three to four
25 week criminal trial and will not be able to complete the mediation within the ninety days
26 originally agreed upon by the parties.
27

Thus, the parties respectfully request the Court extend the mediation completion deadline

28 again for an additional one hundred twenty (120) days from the date of this stipulation and

STIPULATION AND ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION

1 discovery deadlines extended, or to a date otherwise convenient to the Court. The parties propose
2 the following deadlines:
3 Proposed Schedule:
4

The parties propose the following schedule in this matter:

5

a.

Mediation to be completed: October 17, 2020

6

b.

Discovery shall be completed by: June 3, 2020

7

c.

Disclosure of Expert Witnessed due by: July 2, 2020

8

d.

Disclosed expert witnesses of rebuttal: July 20, 2020

9

e.

Expert discovery to be completed by: August 20, 2020

10

e.

Hearing on Dispositive Motions: October 13, 2020.

11
12 DATED: March 23, 2020
13

MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP

14
By:

15
16
17

/s/ Courtney Arnold
David V. Roth
Courtney Arnold
Attorneys for Defendant,
J.C. PENNEY CORPORATION, INC.

18
19
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Dated: March 12, 2020

LAW OFFICES OF JOSEPH A. WELCH

21
22
23

By: _____/s/ Joseph A. Welch
JOSEPH A. WELCH, ESQ.
Attorneys for Plaintiffs, KIMBERLY WARDPETERSON and NOEL PETERSON

24
25
26
27
28
2
STIPULATION AND ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION AND
DISCOVERY

1

UNITED STATES DISTRICT COURT

2

EASTERN DISTRICT OF CALIFORNIA

3
4 KIMBERLY WARD-PETERSON and NOEL
PETERSON,
5
Plaintiffs,
6
v.
7
J.C. PENNEY CORPORATION, INC., J.C.
8 PENNEY COMPANY, INC. and DOES 1
through 10, inclusive,
9
Defendants.
10

Case No. 2:18-cv-00567-KJM-DB
ORDER TO CONTINUE MEDIATION
AND DISCOVERY DEADLINES

11
Having considered the Parties' Stipulation to Continue the Mediation and Discovery
12
Deadline, and good cause having been shown, IT IS HEREBY ORDERED THAT:
13
The mediation and discovery deadlines have been continued to the following:
14
a.

Mediation to be completed: October 17, 2020

b.

Discovery shall be completed by: June 3, 2020

c.

Disclosure of Expert Witnessed due by: July 2, 2020

d.

Disclosed expert witnesses of rebuttal: July 20, 2020

e.

Expert discovery to be completed by: August 20, 2020

e.

Hearing on Dispositive Motions: October 16, 2020.

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16
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21

IT IS SO ORDERED.

22
23 DATED: March 30, 2020.
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ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION AND DISCOVERY