Allen v. Paladin Consulting, Inc. et al

Filing 28

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 10/31/2019. The Discovery Cut-Off date is RESET for 4/17/2020; The Expert Disclosures Cut-Off date is RESET for 5/18/2020; and the Supplemental/Rebuttal Expert Disclosures Cut-Off date is RESET for 6/23/2020. (Becknal, R)

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JEREMY PASTERNAK, ESQ., BAR NO: 181618
[e-mail]
MORGAN YANG, ESQ., BAR NO: 324742
[e-mail]
LAW OFFICES OF JEREMY PASTERNAK
A Professional Corporation
354 Pine Street, Fifth Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
DANIEL ALLEN

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[ADDITIONAL COUNSEL ON NEXT PAGE]

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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DANIEL ALLEN, an individual

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Plaintiff,
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v.
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PALADIN CONSULTING, INC., a Texas
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Corporation; XEROX CORPORATION, a New York )
Corporation; GEE GROUP, INC., an Illinois
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Corporation; GENERAL EMPLOYMENT
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ENTERPRISE, INC., an Illinois Corporation; and
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Does 1-20, inclusive,
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Defendants.
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Case No. 2:18-cv-00706-TLN-CKD
STIPULATION AND ORDER
REGARDING
DISCOVERY DATES

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Stipulation and Order Regarding Discovery Dates
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HEATHER HEARNE (SBN 254496)
[e-mail]
THE KULLMAN FIRM, PLC
4605 Bluebonnet Blvd., Suite A
Baton Rouge, LA 70809
Telephone: [phone]
Facsimile: [phone]
RACHEL E. LINZY (PHV)
[e-mail]
THE KULLMAN FIRM
A Professional Law Corporation
1100 Poydras Street, suite 1600
New Orleans, LA 70163
Tel: [phone]
Fax: [phone]

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Attorneys for Defendant
XEROX CORPORATION

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SARAH E. ROBERTSON (SBN 142439)
[e-mail]
JASMINE L. ANDERSON (SBN 252973)
[e-mail]
COSTANGY, BROOKS, SMITH, & PROPHETE, LLP
351 California St., Suite 200
San Francisco, CA 94104
Telephone: [phone]
Facsimile: 415.918.3007
Attorneys for Defendants
PALADIN CONSULTING, INC
GEE GROUP, INC., and GENERAL
EMPLOYMENT ENTERPRISES, INC.

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Stipulation and Order Regarding Discovery Dates
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The parties, through their respective counsel, hereby stipulate as follows:

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WHEREAS, Plaintiff brought this action relating to his former employment against the

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following entities: PALADIN CONSULTING, INC., a Texas Corporation; XEROX

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CORPORATION, a New York Corporation; GEE GROUP, INC., an Illinois Corporation;

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GENERAL EMPLOYMENT ENTERPRISE, INC., an Illinois Corporation; and Does 1-20,

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inclusive, on February 6, 2018; and

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WHEREAS, Defendant XEROX CORPORATION filed their Answer on April 6, 2018; and

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WHEREAS, Plaintiff filed an amended complaint on April 27, 2018; and

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WHEREAS, Defendant XEROX CORPORATION filed their answer to Plaintiff’s

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First

Amended Complaint on May 14, 2018; and

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WHEREAS, Defendant PALADIN CONSULTING, INC, GEE GROUP, INC., and

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GENERAL EMPLOYMENT ENTERPRISE, INC., filed their answer to Plaintiff’s First Amended

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Complaint on May 11, 2018; and

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WHEREAS, the parties have exchanged and are conducting written discovery; and

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WHEREAS, Plaintiff suffered a stroke on or about August, 2018; and

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WHEREAS, Plaintiff’s stroke affected his speech such that he was unable to have his

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deposition taken in this matter as previously planned; and

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WHEREAS, because of this delay and out of a professional courtesy to Defendants,

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Plaintiff’s counsel has intentionally not moved forward with depositions of Defendants’ employees;

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and

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WHEREAS, Plaintiff and Defendants agreed to stipulate to continue Discovery and
Mediation deadlines; and

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WHEREAS, Plaintiff has now recovered sufficiently to have his deposition taken in this
matter; and

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WHEREAS, the Court has ordered the parties to provide new discovery dates; and
THEREFORE, the Parties hereby stipulate and request as follows: 27
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Stipulation and Order Regarding Discovery Dates
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The Court set the Discovery Cut-Off date for April 17, 2020;

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The Court set the Expert Disclosures Cut-Off date for May 18, 2020;

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The Court set the Supplemental/Rebuttal Expert Disclosures Cut-Off date for June 23, 2020.

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Date: October 30, 2019

LAW OFFICES OF JEREMY PASTERNAK
A Professional Corporation

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By:
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/s/_ o_gan Yang
_ M r__ ___
JEREMY PASTERNAK
MORGAN YANG
Attorneys for Plaintiff
DANIEL ALLEN

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Date: October 30, 2019

THE KULLMAN FIRM, PLC

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By:

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/_ R_ c______zy _ it__p _ m s_ion)
s/ a_ hel Lin __(w h _er__i_ s
HEATHER HEARNE
RACHEL E. LINZY
Attorneys for Defendant
XEROX CORPORATION

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Date: October 30, 2019
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CONSTANGY, BROOKS, SMITH, &
PROPHETE, LLP

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By:

/s__ a_mine Ander__n (__i_h p_
_ / J_ s _ ____ so w t ermission)
SARAH E. ROBERTSON
JASMINE L. ANDERSON
Attorneys for Defendant
PALADIN CONSULTING, INC; GEE
G R O U P , IN C . , a n d G EN E R A L
EMPLOYMENT ENTERPRISES, INC.

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Stipulation and Order Regarding Discovery Dates
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ORDER
The Court, having reviewed having reviewed the Stipulation of the parties and Request for

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Order, and GOOD CAUSE HAVING BEEN SHOWN, hereby orders:

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The Discovery Cut-Off date be set for April 17, 2020;

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The Expert Disclosures Cut-Off date be set for May 18, 2020;

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The Supplemental/Rebuttal Expert Disclosures Cut-Off date be set for June 23, 2020.

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IT IS SO ORDERED.

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Dated: October 31, 2019
Troy L. Nunley
United States District Judge

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Stipulation and Order Regarding Discovery Dates
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