Allen v. Paladin Consulting, Inc. et al

Filing 37

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 1/19/2021 ORDERING the Discovery Cut-Off date is RE-SET for 4/19/2021; The Expert Disclosures Cut-Off date is RE-SET for 5/17/2021; The Supplemental/Rebuttal Expert Disclosures Cut-Off date is RE-SET for 6/21/2021. (Zignago, K.)

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JEREMY PASTERNAK, ESQ. (SBN 181618)
[e-mail]

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MORGAN YANG, ESQ. (SBN 324742)
[e-mail]

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LAW OFFICES OF JEREMY PASTERNAK
A Professional Corporation
354 Pine St., Fifth Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff
DANIEL ALLEN

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[ADDITIONAL COUNSEL ON NEXT PAGE]

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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DANIEL ALLEN, on behalf of
himself,

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Plaintiff,
v.

No. 2:18-cv-00706-TLN-CKD
STIPULATION AND ORDER
CONTINUING PENDING
DISCOVERY DEADLINES

PALADIN CONSULTING, INC., a
Texas Corporation; XEROX
CORPORATION, a New York
Corporation; GEE GROUP, INC., an
Illinois Corporation; GENERAL
EMPLOYMENT ENTERPRISES,
INC., an Illinois Corporation; and Does
1-20, inclusive.
Defendants.

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Stipulation and Order to Continue Pending Discovery

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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]
Attorneys for Defendant
XEROX CORPORATION
SARAH E. ROBERTSON (SBN 142439)
[e-mail]
JASMINE L. ANDERSON (SBN 252973)
[e-mail]
COSTANGY, BROOKS, SMITH, & PROPHETE, LLP
601 Montgomery Street, Suite 350
San Francisco, CA 94111
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 to Continue Pending Discovery

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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

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

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protecting the health, safety, and wellbeing of all parties, witnesses, attorneys and

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court personnel, Plaintiff Daniel Allen (“Plaintiff”) and Defendants Paladin

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Consulting, Xerox Corporation, Gee Group, Inc., and General Employment

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

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

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related deadlines currently set by four (4) months.

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

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previously stipulated to, pursuant to their October 31, 2019, April 14, 2020, and

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August 14, 2020 Stipulations. Therefore, the Parties hereby stipulate and request as

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follows:

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The Court set the Discovery Cut-Off date for April 19, 2021;

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The Court set the Expert Disclosures Cut-Off date for May 17, 2021;

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The Court set the Supplemental/Rebuttal Expert Disclosures Cut-Off date for

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June 21, 2021.

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The Parties shall file a joint report on the status of all case related deadlines to

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the Court every 60 days following the approval of this Stipulation and [Proposed]

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Order.

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IT IS SO STIPULATED:

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Stipulation and Order to Continue Pending Discovery

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Dated: January 15, 2021

LAW OFFICES OF JEREMY PASTERNAK
A Professional Corporation

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By: /s/ Morgan Yang_________________________
JEREMY PASTERNAK
MORGAN YANG
Attorneys for Plaintiff
DANIEL ALLEN

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Dated: January 12, 2021

By:/s/ Rachel E. Linzy (with permission 1/12/21)
HEATHER HEARNE
RACHEL E. LINZY
Attorneys for Defendant
XEROX CORPORATION

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THE KULLMAN FIRM, PLC

Dated: January 15, 2021

COSTANGY, BROOKS, SMITH, & PROPHETE,
LLP

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By: /s/ Jasmine L. Anderson (with permission 1/15/21)
SARAH E. ROBERTSON
JASMINE L. ANDERSON
Attorneys for Defendant
PALADIN CONSULTING, INC; GEE
GROUP, INC., and GENERAL
EMPLOYMENT ENTERPRISES, INC.

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Stipulation and Order to Continue Pending Discovery

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ORDER

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The Court, having reviewed the Stipulation of the parties and Request for
Order, and GOOD CAUSE HAVING BEEN SHOWN, hereby orders:

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The Discovery Cut-Off date is re-set for April 19, 2021;

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The Expert Disclosures Cut-Off date is re-set for May 17, 2021;

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The Supplemental/Rebuttal Expert Disclosures Cut-Off date is re-set for June

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21, 2021.

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IT IS SO ORDERED.

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Dated: January 19, 2021
Troy L. Nunley
United States District Judge

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Stipulation and Order to Continue Pending Discovery

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Proof of Service

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