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.)

Download PDF
1 2 3 4 5 6 7 8 9 10 11 12 13 14 PACIFIC JUSTICE INSTITUTE KEVIN T. SNIDER, SBN 170988 MATTHEW B. MCREYNOLDS, SBN 234797 P.O. Box 276600 Sacramento, CA 95827 Telephone: (916) 857-6900 Facsimile: (916) 857-6902 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: (916) 341-0404 Facsimile: (916) 341-0141 Attorneys for Defendant, THE PERMANENTE MEDICAL GROUP, INC. 15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION 17 JULIE AMORUSO, 18 Plaintiff, 19 20 21 22 23 24 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, 25 July 6, 2020 TBD Defendants. 26 27 /// 28 /// Joint Stipulation and Request for Continuance for Parties to Complete ADR 1 Julie Amoruso v. TPMG, et al. USDC-Eastern Case No. 2:20-CV-01335 1 Counsel for Plaintiff JULIE AMORUSO (“Plaintiff”) and Defendant THE 2 PERMANENTE MEDICAL GROUP, INC. (“Defendant”), (collectively referred to as the 3 “Parties”), hereby enter into the following Joint Stipulation and request the Court to extend 4 certain pretrial deadlines, pursuant to applicable Local Rules. These are the only two Parties to 5 this Action. 6 1. This is an Action for alleged violation of Title VII of the Civil Rights Act of 1964 7 and the California Fair Employment and Housing Act, for Failure or Refusal to Hire on Basis of 8 Religion; Failure to Provide Religious Accommodation; and Disparate Impact on the Basis of 9 Religion. The Parties have engaged in extensive written discovery and completed several 10 depositions. After the conclusion of recent depositions, the Parties have agreed to engage in ADR 11 in a good faith effort to resolve this matter. 12 scheduled for this week and jointly request a stay of the current deadlines. No trial date has been 13 set at this time. Furthermore, one witness remains unavailable for deposition due to an ongoing 14 leave issue. The Parties are meeting and conferring further today and tomorrow to select a 15 mediator and mediation date. 16 2. The Parties postponed remaining depositions The Court has previously granted continuances in this matter to allow the Parties 17 to complete discovery. As the Parties now wish to engage in ADR, good cause exists for a 18 further continuance to allow for the ADR process, and to allow the remaining witness to return 19 from leave and appear for deposition if necessary. Because no trial date has been set in this 20 matter, the Parties agree no prejudice will be suffered by the Parties and the Court’s docket will 21 not be adversely impacted by granting this request. 22 3. 23 mediation, prior to the completion of discovery, by moving the current deadlines by 120 days. 24 More specifically, the Parties request the following pretrial deadlines to be continued as follows: 25 /// 26 /// 27 /// 28 /// 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 2 Julie Amoruso v. TPMG, et al. USDC-Eastern Case No. 2:20-CV-01335

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?