Amoruso v. Permanente Medical Group, et al.

Filing 23

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 08/02/22 EXTENDING the following dates: Fact discovery cutoff: 11/25/22; Rebuttal Expert Witness Exchange: 12/20/22; Expert Discovery Cut-Off: 01/20/22; Dispositive Motions: 03/10/23. Parties to submit a joint report within 10 business day after the completion of mediation. (Benson, A.)

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PACIFIC JUSTICE INSTITUTE
KEVIN T. SNIDER, SBN 170988
MATTHEW B. MCREYNOLDS, SBN 234797
P.O. Box 276600
Sacramento, CA 95827
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff,
JULIE AMORUSO
JACKSON LEWIS P.C.
MICHAEL J. CHRISTIAN (SBN 173727)
SHANE R. LARSEN (SBN 283966)
400 Capitol Mall, Suite 1600
Sacramento, California 95814
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
Attorneys for Defendant,
THE PERMANENTE MEDICAL GROUP, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION

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JULIE AMORUSO,

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Plaintiff,

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Case No. 2:20-CV-01335-KJM-DB
JOINT STIPULATION AND REQUEST
FOR CONTINUANCE FOR PARTIES TO
COMPLETE ADR AND ORDER

v.

THE PERMANENTE MEDICAL GROUP, a
California corporation; and KAISER
FOUNDATION HOSPITALS, a California
Complaint Filed:
corporation, collectively dba KAISER
Trial Date:
PERMANENTE SOUTH SACRAMENTO
MEDICAL CENTER, KAISER PERMANENTE
ROSEVILLE MEDICAL CENTER and
KAISER PERMANENTE STOCKTON
FACILITY,

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July 6, 2020
TBD

Defendants.

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Joint Stipulation and Request for Continuance for Parties to
Complete ADR

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Julie Amoruso v. TPMG, et al.
USDC-Eastern Case No. 2:20-CV-01335

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Counsel

for

Plaintiff

JULIE

AMORUSO

(“Plaintiff”)

and

Defendant

THE

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PERMANENTE MEDICAL GROUP, INC. (“Defendant”), (collectively referred to as the

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“Parties”), hereby enter into the following Joint Stipulation and request the Court to extend

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certain pretrial deadlines, pursuant to applicable Local Rules. These are the only two Parties to

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this Action.

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1.

This is an Action for alleged violation of Title VII of the Civil Rights Act of 1964

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and the California Fair Employment and Housing Act, for Failure or Refusal to Hire on Basis of

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Religion; Failure to Provide Religious Accommodation; and Disparate Impact on the Basis of

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Religion.

The Parties have engaged in extensive written discovery and completed several

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depositions. After the conclusion of recent depositions, the Parties have agreed to engage in ADR

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in a good faith effort to resolve this matter.

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scheduled for this week and jointly request a stay of the current deadlines. No trial date has been

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set at this time. Furthermore, one witness remains unavailable for deposition due to an ongoing

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leave issue. The Parties are meeting and conferring further today and tomorrow to select a

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mediator and mediation date.

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2.

The Parties postponed remaining depositions

The Court has previously granted continuances in this matter to allow the Parties

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to complete discovery. As the Parties now wish to engage in ADR, good cause exists for a

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further continuance to allow for the ADR process, and to allow the remaining witness to return

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from leave and appear for deposition if necessary. Because no trial date has been set in this

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matter, the Parties agree no prejudice will be suffered by the Parties and the Court’s docket will

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not be adversely impacted by granting this request.

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3.

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mediation, prior to the completion of discovery, by moving the current deadlines by 120 days.

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More specifically, the Parties request the following pretrial deadlines to be continued as follows:

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The Parties hereby jointly request the Court to grant the Parties further time to engage in

Joint Stipulation and Request for Continuance for Parties to
Complete ADR

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Julie Amoruso v. TPMG, et al.
USDC-Eastern Case No. 2:20-CV-01335