Nevitt . v. Regents of the University of CA

Filing 72

STIPULATION and ORDER signed by Senior District Judge Morrison C. England, Jr on 06/05/24 CONTINUING the following dates: Plaintiff's Opposition: 09/11/24; Defendants' Reply: 09/27/24. (Licea Chavez, V)

1 SANDRA L. McDONOUGH (SBN 193308)
[e-mail]
2 BRIANA M. ANTUNA (SBN 345529)
[e-mail]
3 QUARLES & BRADY LLP
101 West Broadway, Ninth Floor
4 San Diego, California 92101-8285
Telephone: [phone]
5 Facsimile: 619-615-0700
6 Attorneys for Defendants The Regents of the
University of California, Gary May and Edwin
7 Grosholz
8
DAN SIEGEL (SBN 56400)
9 [e-mail]
SONYA MEHTA (SBN 294411)
10 [e-mail]
SIEGEL, YEE, BRUNNER & MEHTA
11 475 14th Street, Suite 500
Oakland, CA 94612
12 Telephone: [phone]
Facsimile: 510-444-6698
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Attorneys for Plaintiff, Gabrielle Nevitt, Ph.D.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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18 GABRIELLE NEVITT, Ph.D.,

Case No. 2:20-CV-02311-MCE-CKD

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JOINT STIPULATION TO CONTINUE
THE DATE OF PLAINTIFF’S RESPONSE
TO DEFENDANTS’ MOTION FOR
SUMMARY JUDGMENT; ORDER

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Plaintiff,
v.

21 THE REGENTS OF THE UNIVERSITY OF
CALIFORNIA,
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Defendant.
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Judge:
Hon. Morrison C. England, Jr.
Magistrate Judge: Hon. Carolyn K. Delaney
Crtrm.:
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Trial Date:
None Set

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Case No. 2:20-CV-02311-MCE-CKD
JOINT STIPULATION TO CONTINUE THE DATE OF PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION
FOR SUMMARY JUDGMENT

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This Joint Stipulation is made by and between Plaintiff Gabrielle Nevitt (“Plaintiff”) and

2 Defendants The Regents of the University of California, Gary May and Edwin Grosholz
3 (collectively, “Defendants”), through their respective counsel, in light of the following facts:
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RECITALS
1.

The parties to the above-entitled action hereby submit this Joint Stipulation to

6 Continue the Date of Plaintiff’s Response to Defendants’ Motion for Summary Judgment.
7 Specifically, the parties seek to continue the response date by four weeks.
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2.

Per the Order Granting Plaintiff’s Motion for Leave to File Supplemental

9 Complaint Case 2:20-cv-02311-MCE-CKD, Document 68, Filed April 15, 2024, the Court set the
10 following deadlines, in relevant part:
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"Discovery shall be reopened only as to the supplemental allegations. All discovery shall

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be completed not later than ninety (90) days following the date this Order is electronically

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filed. Any motion for summary judgment shall be filed not later than thirty (30) days

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following the close of discovery.”

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3.

Per Local Rule 230(c), (d), Opposition briefs shall be filed no later than fourteen

16 (14) days after the motion was filed. No later than ten (10) days after the Opposition is filed, the
17 moving party may serve and file a Reply to any Opposition filed by a responding party.
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4.

Per Local Rule 230(b), "the matter shall be set for hearing on the motion calendar

19 of the Judge or Magistrate Judge to whom the action has been assigned or before whom the
20 motion is to be heard not less than thirty-five (35) days after service and filing of the motion."
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5.

The current last day to file a motion for summary judgment is August 14, 2024.

22 This renders Plaintiff’s opposition currently due August 28, 2024, and Defendants’ Reply Brief
23 due September 7, 2024. The earliest the hearing may take place is September 18, 2024.
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6.

Given that this is a fact intensive case, the Parties stipulate to the following revised

25 briefing schedule for the Opposition and Reply briefs only: Opposition briefs shall be filed no later
26 than twenty-eight (28) days after the motion was filed. No later than fourteen (14) days after the
27 Opposition is filed, the moving party may serve and file a Reply to any Opposition filed by a
28 responding party. This renders Plaintiff’s Opposition due September 13, 2024, and Defendants’
Case No. 2:20-CV-02311-MCE-CKD
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JOINT STIPULATION TO CONTINUE THE DATE OF PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION
FOR SUMMARY JUDGMENT

1 Reply Brief due September 27, 2024. The earliest the hearing may take place is September 18,
2 2024, but the parties assume this date will be extended out to a date convenient to the Court to
3 give the Court sufficient time to read the papers (eleven (11) days which are the minimum under
4 the stated briefing schedule).
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STIPULATION

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NOW, THEREFORE, Plaintiff and Defendants hereby stipulate and agree through their

7 counsel of record as follows:
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7.

The briefing deadlines are extended on Defendants’ Motion for Summary

9 Judgment, or, in the Alternative, Summary Adjudication, such that Plaintiff’s Opposition to the
10 Motion is filed no later than twenty-eight (28) days after the motion was filed and Defendants’
11 Reply brief in support of their Motion is due no later than fourteen (14) days after the Opposition
12 is filed.
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8.

This stipulation, including recitals, may not be used for any purpose other than this

14 requested continuance.
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16 Dated: May 31, 2024

QUARLES & BRADY LLP

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By:

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Dated: May 31, 2024

/s/ Sandra L. McDonough
SANDRA L. McDONOUGH
BRIANA M. ANTUNA
Attorneys for Defendants The Regents of the
University of California, Gary May and Edwin
Grosholz

SIEGEL, YEE, BRUNNER & MEHTA

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By:

/s/ Sonya Z. Mehta
DAN SIEGEL
SONYA Z. MEHTA
Attorneys for Plaintiff Gabrielle Nevitt

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Case No. 2:20-CV-02311-MCE-CKD
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JOINT STIPULATION TO CONTINUE THE DATE OF PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION
FOR SUMMARY JUDGMENT

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ORDER
The Court, having reviewed the Parties’ Joint Stipulation to Continue the Date of

3 Plaintiff’s Response to Defendants’ Motion for Summary Judgment, and good cause appearing
4 therefore, hereby orders as follows:
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1.

The following revised briefing schedule shall apply to the Opposition and Reply

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briefs only: Opposition briefs shall be filed no later than twenty-eight (28) days

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after the motion was filed. No later than fourteen (14) days after the Opposition is

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filed, the moving party may serve and file a Reply to any Opposition filed by a

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responding party. This renders Plaintiff’s Opposition due September 11, 2024, and

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Defendants’ Reply Brief due September 27, 2024. If a hearing is necessary, the

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Court will set it after the briefing is complete.

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IT IS SO ORDERED.

13 Dated: June 5, 2024
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Case No. 2:20-CV-02311-MCE-CKD
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JOINT STIPULATION TO CONTINUE THE DATE OF PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION
FOR SUMMARY JUDGMENT