Randhawa v. Intel Corporation

Filing 20

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 2/25/2022 MODIFYING the Scheduling Order as follows: Fact Discovery cutoff is 11/30/2022. Designation of Expert Witnesses due by 12/16/2022. Rebuttal Expert Witneeses due by 12/30/2022. All Expert Discovery completed by 1/13/2023. Dispositive Motions heard by 4/21/2023. (Coll, A)

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Scott Philip Jang (State Bar No. 260191)
Hardev S. Chhokar (State Bar No. 311802)
JACKSON LEWIS P.C.
50 California Street, 9th Floor
San Francisco, California 94111-4615
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for Defendant
INTEL CORPORATION

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SONIA RANDHAWA,

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Plaintiff(s),
v.
INTEL CORPORATION,

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Defendant(s).

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Case No. 2:21-cv-00054-KJM-DB
STIPULATION AND ORDER TO
MODIFY SCHEDULING ORDER RE:
DISCOVERY AND DISPOSITIVE
MOTION DEADLINES

FAC Filed:
Trial Date:

03/11/2021
None

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Defendant INTEL CORPORATION (“Defendant”) and Plaintiff SONIA RANDHAWA

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(“Plaintiff”) (collectively, the “Parties”) stipulate as follows and respectfully request the Court to

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modify the current scheduling order regarding fact discovery, expert designations, expert reports,

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expert discovery, and dispositive motions.

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1.

WHEREFORE, Defendant filed a Motion to Dismiss on April 2, 2021 pursuant to

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Federal Rule of Civil Procedure 12(b)(6) regarding Plaintiff’s third cause of action

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for retaliation under Title VII of the Civil Rights Act and Plaintiff’s fourth cause

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of action for retaliation under California’s Fair Employment and Housing Act. The

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Court heard the Motion to Dismiss on May 7, 2021 and took it under submission,

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but has not yet issued a ruling.

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STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER RE: DISCOVERY AND DISPOSITIVE
MOTION DEADLINES
Case No. 2:21-cv-0054 KJM DB

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2.

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WHEREFORE, the Court’s ruling on the Motion to Dismiss may affect the scope
of discovery.

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3.

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WHEREFORE, on May 7, 2021, the Court also held a scheduling conference and
set a pre-trial case scheduling order.

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4.

WHEREFORE, the current pre-trial case scheduling order sets the following

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deadlines: (1) fact discovery completed by May 30, 2022, (2) expert disclosures

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completed by June 14, 2022, (3) rebuttal expert witnesses exchanged by June 28,

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2022, (4) all expert discovery completed by July 11, 2022, and (5) dispositive

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motions heard by October 7, 2022.

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5.

WHEREFORE, the Parties have met and conferred and agreed that they would

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need additional time to conduct necessary discovery and file dispositive motions

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because Defendant’s Motion to Dismiss has not yet been decided.

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6.

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THEREFORE, the Parties stipulate and respectfully request the Court to modify
the current scheduling order as follows:

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Event

Current Date

New Proposed Date

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Fact Discovery Cutoff

5/30/2022

11/30/2022

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Expert Disclosure

6/14/2022

12/16/2022

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Rebuttal Expert Witnesses

6/28/2022

12/30/2022

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Exchange

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All Expert Discovery

7/11/2022

1/13/2023

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Completed

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Dispositive Motions Heard

10/7/2022

4/7/2023

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By

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///

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///

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///

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STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER RE: DISCOVERY AND DISPOSITIVE
MOTION DEADLINES
Case No. 2:21-cv-0054 KJM DB

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IT IS SO STIPULATED.

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Dated: February 17, 2022

JACKSON LEWIS P.C.

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By:

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/s/ Hardev S. Chhokar
Scott Philip Jang
Hardev S. Chhokar
Attorneys for Defendant
INTEL CORPORATION

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Dated: February 17, 2022

MARTIN & VANEGAS, APC

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By: /s/ Luke Peters
Marta R. Vanegas
Luke Peters
Attorneys for Plaintiff
SONIA RANDHAWA

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ORDER

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Pursuant to the Parties’ stipulation and good cause appearing, the scheduling order (ECF
Doc. No. 16) is modified as follows:
Event

New Date

Fact Discovery Cutoff

November 30, 2022

Expert Disclosure

December 16, 2022

Rebuttal Expert Witnesses Exchange December 30, 2022
All Expert Discovery Completed

January 13, 2023

Dispositive Motions Heard By

April 21, 2023

IT IS SO ORDERED.
DATED: February 25, 2022.

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STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER RE: DISCOVERY AND DISPOSITIVE
MOTION DEADLINES
Case No. 2:21-cv-0054 KJM DB