Randhawa v. Intel Corporation

Filing 30

ORDER signed by Chief District Judge Kimberly J. Mueller on 12/23/2022 EXTENDING the Scheduling Order as follows: Fact Discovery Cut-Off is 04/30/2023. Designation of Expert Witnesses due by 05/15/2023. Rebuttal Expert Witnesses exchanged by 05/30/2023. All Expert Discovery completed by 06/14/2023. Dispositive Motions heard by 10/13/2023. (Rodriguez, E)

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Scott Philip Jang (State Bar No. 260191)
Robert Yang (State Bar No. 312964)
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
Marta R. Vanegas (State Bar No. 278328)
Brittany C. Toth (State Bar No. 324593)
VANEGAS LAW GROUP, APC
3100 Oak Road, Suite 230
Walnut Creek, CA 95497
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
SONIA RANDHAWA

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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),

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v.
INTEL CORPORATION,

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Defendant(s).

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Case No. 2:21-cv-00054-KJM-DB
JOINT STIPULATION AND
AMENDED ORDER TO EXTEND
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”) by and through their respective counsel of record,

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hereby stipulate and agree as follows:

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JOINT STIPULATION AND AMENDED ORDER TO EXTEND DISCOVERY
AND DISPOSITIVE MOTION DEADLINES

Case No. 2:21-cv-0054 KJM DB

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1.

WHEREFORE, on or about November 8, 2022, the Court granted the Parties’

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Stipulation to Modify Scheduling Order Re: Discovery and Dispositive Motion

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Deadlines [ECF Doc. No. 27].

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2.

WHEREFORE, the current scheduling order sets the following deadlines: (1) fact

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discovery completed by January 30, 2022; (2) expert disclosures completed by

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February 17, 2023; (3) rebuttal expert witnesses exchanged by February 28, 2023;

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(4) all expert discovery completed by March 13, 2023; and (5) dispositive motions

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heard by June 30, 2023.

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3.

WHEREFORE, the Parties have been actively trying to complete discovery since

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the Court issued its Order denying Defendant’s Motion to Dismiss, on March 31,

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2022 [ECF Doc. No. 21], to meet the current discovery deadline of January 30,

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2023;

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4.

WHEREFORE, the Parties have met and conferred and agreed that the Parties need

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additional time to exchange discovery, including the need to conduct E-Discovery,

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which includes additional data custodians identified by Plaintiff.

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5.

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

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Event

Current Date

New Proposed Date

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Fact Discovery Cutoff

01/30/2023

04/30/2023

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Expert Disclosure

02/17/2023

05/15/2023

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Rebuttal Expert Witness

02/28/2023

05/30/2023

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Exchange

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All Expert Discovery

03/13/2023

06/14/2023

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Completed

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Dispositive Motion Heard By

06/07/2023

10/07/2023

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JOINT STIPULATION AND AMENDED ORDER TO EXTEND 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: December 15, 2022

JACKSON LEWIS P.C.

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By:

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Dated: December 15, 2022

/s/ Scott P. Jang
Scott Philip Jang
Robert Yang
Attorneys for Defendant
INTEL CORPORATION
MARTIN & VANEGAS, APC

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By: /s/ Iustina G. Mignea _______________
Marta R. Vanegas
Brittany C. Toth
Iustina G. Mignea
Attorneys for Plaintiff
SONIA RANDHAWA

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AMENDED ORDER

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Pursuant to the Parties’ amended stipulation and good cause appearing, the scheduling
order (ECF Doc. No. 27) is modified as follows:

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Event

New Date

Fact Discovery Cutoff

04/30/2023

Expert Disclosure

05/15/2023

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Rebuttal Expert Witnesses Exchange 05/30/2023

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All Expert Discovery Completed

06/14/2023

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Dispositive Motions Heard By

10/13/2023

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The court does not have hearings on October 7, 2023. Thus dispositive motions shall be

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heard by October 13, 2023.

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IT IS SO ORDERED.

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DATED: December 23, 2022.

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JOINT STIPULATION AND AMENDED ORDER TO EXTEND DISCOVERY
AND DISPOSITIVE MOTION DEADLINES

Case No. 2:21-cv-0054 KJM DB