Allen v. Paladin Consulting, Inc. et al

Filing 32

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/15/2020 APPROVING 31 Stipulation and EXTENDING an additional 6 Months, all hearings, discovery deadlines, and other case related deadlines currently set. The Parties shall file a joint report on the status of all case related deadlines to the court every 90 days. (York, M)

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JEREMY PASTERNAK (SBN 181618)
[e-mail]
MORGAN YANG (SBN 324742)
[e-mail]
LAW OFFICES OF JEREMY PASTERNAK
A Professional Corporation
354 Pine St., 5th Floor
San Francisco, CA 94104
Phone: [phone]
Fax: [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,

Case No. 2:18-cv-00706-TLN-CKD

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Plaintiff,

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v.

STIPULATION AND ORDER TO
EXTEND ALL DEADLINES BY SIX
(6) MONTHS DUE TO COVID-19

PALADIN CONSULTING, INC., a Texas
Corporation; XEROX CORPORATION, a New Complaint Filed: February 7, 2018
York Corporation; GEE GROUP, INC., an
Illinois Corporation; GENERAL
EMPLOYMENT ENTERPRISES, INC., an
Illinois Corporation; and Does 1-20, inclusive,

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Defendants.

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STIPULATION AND ORDER TO EXTEND ALL CASE DEADLINES

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SARAH E. ROBERTSON (SBN 142439)
[e-mail]
JASMINE L. ANDERSON (SBN 259973)
[e-mail]
CONSTANGY, BROOKS, SMITH & PROPHETE, LLP
601 Montgomery Street, Suite 350
San Francisco, CA 94111
Phone: [phone]
Attorney for Defendants
PALADIN CONSULTING, INC.
GEE GROUP, INC., and GENERAL
EMPLOYMENT ENTERPRISES, INC.
HEATHER HEARNE (SBN 254496)
[e-mail]
THE KULLMAN FIRM, PLC
4605 Bluebonnet Blvd., Suite A
Baton Rouge, LA 70809
Phone: [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]
Attorneys for Defendant
XEROX CORPORATION

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STIPULATION AND ORDER TO EXTEND ALL CASE DEADLINES

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TO THE COURT AND ALL PARTIES OF RECORD:

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PLEASE TAKE NOTICE THAT, as a result of the unprecedented travel and safety

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restrictions relating to the Coronavirus (“COVID-19”), and in the interest of protecting the health,

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safety, and wellbeing of all parties, witnesses, attorneys and court personnel, Plaintiff Daniel Allen

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(“Plaintiff”) and Defendants Paladin Consulting, Xerox Corporation, Gee Group, Inc., and General

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Employment Enterprises, Inc. (“Defendants”), (collectively, the “Parties”) hereby agree and

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stipulate to extend all hearings, discovery deadlines, depositions, and other case related deadlines

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currently set by six (6) months.

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This Stipulation is intended to expressly apply to all dates the Parties had previously

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stipulated to, pursuant to their October 31, 2019, stipulation and order, attached for reference hereto

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as “Exhibit A”.

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The Parties shall file a joint report on the status of all case related deadlines to the court
every 90 days following the approval of this Stipulation and [Proposed] Order.

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STIPULATION AND ORDER TO EXTEND ALL CASE DEADLINES

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IT IS SO STIPULATED:

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DATED: April 15, 2020

THE LAW OFFICES OF JEREMY PASTERNAK

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By /s/ Jeremy Pasternak (as authorized on 4/13/2020)
Jeremy Pasternak
Morgan Yang
Attorneys for Plaintiff
DANIEL ALLEN

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DATED: April 15, 2020

CONSTANGY, BROOKS, SMITH & PROPHETE, LLP

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By /s/ Sarah E. Robertson ________
Sarah E. Robertson
Jasmine L. Anderson
Attorney for Defendants
PALADIN CONSULTING, INC.; GEE GROUP, INC.;
GENERAL EMPLOYMENT ENTERPRISES, INC.

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DATED: April 15, 2020

THE KULLMAN FIRM

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By /s/ Rachel Linzy (as authorized on 4/14/2020)
Heather Hearne
Rachel E. Linzy
Attorneys for Defendant
XEROX CORPORATION

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ORDER
Pursuant to the Parties stipulation, all hearings, discovery deadlines, and other case related
deadlines currently set, are extended an additional six (6) months.
IT IS SO ORDERED.
DATED: April 15, 2020

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Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER TO EXTEND ALL CASE DEADLINES