Smith v. G & B Grocers

Filing 13

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 11/20/2022 CONTINUING deadlines in initial pretrial scheduling order as follows: all non-expert discovery due by 12/21/2022; fact discovery due by 1/20/2023; dispositive motions due by 2/20/2023; exchange expert disclosures due by 3/23/2023; and serve supplemental list of expert disclosures due by 4/19/2023. (Perdue, C.)

Case 2:21-cv-01504-MCE-AC Document 13 Filed 11/21/22 Page 1 of 4

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Alden J. Parker (SBN 196808)
E-Mail: [e-mail]
Christopher S. Alvarez (SBN 294795)
E-Mail: [e-mail]
FISHER & PHILLIPS LLP
621 Capitol Mall, Suite 1400
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
G & B GROCERS dba RANCHO CORDOVA
GROCERY OUTLET [erroneously sued as G & B GROCERS
doing business as Grocery Outlet]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MAURSHAE SMITH, on behalf of herself and
all others similarly situated,

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Plaintiff,
v.

Case No: 2:21-cv-01504-MCE-AC
JOINT STIPULATION TO CONTINUE
DEADLINES IN INITIAL PRETRIAL
SCHEDULING ORDER; ORDER

G & B GROCERS, a California corporation,
doing business as Grocery Outlet, and DOES 110,

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Defendants.

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Complaint Filed: August 22, 2021
Trial Date: None Set

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JOINT STIPULATION TO CONTINUE DEADLINES IN INITIAL PRETRIAL SCHEDULING ORDER; ORDER
FP 45663345.1

Case 2:21-cv-01504-MCE-AC Document 13 Filed 11/21/22 Page 2 of 4

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IT IS HEREBY STIPULATED AND AGREED, between Plaintiff MAURSHAE SMITH’s

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(“Plaintiff”), G & B GROCERS dba RANCHO CORDOVA GROCERY OUTLET [erroneously sued

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as G & B GROCERS doing business as Grocery Outlet] (“Defendant”), through their respective counsel

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of record, as follows:

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WHEREAS, on August 23, 2021, the Court entered an Initial Scheduling Order (ECF No. 4);

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WHEREAS, on September 20, 2022, the Parties submitted a Joint Stipulation to Continue

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Deadlines in Initial Pretrial Scheduling Order (ECF No. 10);
WHEREAS, on September 27, 2022, the Court entered its Order on Joint Stipulation to Continue

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Deadlines in Initial Pretrial Scheduling Order (ECF No. 11);

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WHEREAS, this Joint Stipulation is not entered into with the intent to delay;

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WHEREAS, by continuing the discovery and other deadlines set forth herein, there is no

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prejudice to any party;

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WHEREAS, the parties desire to avoid unnecessary costs associated with these deadlines before

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completing essential non-expert, and fact discovery while the Parties continue to discuss potential

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resolution, as incurring said costs on both sides may be an impediment to resolving this case;
WHEREAS, good cause exists for granting the Parties’ request to extend the following deadlines

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by thirty (30) days in accordance with Federal Rules of Civil Procedure Rule 29;

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JOINT STIPULATION TO CONTINUE DEADLINES IN INITIAL PRETRIAL SCHEDULING ORDER; ORDER
FP 45663345.1

Case 2:21-cv-01504-MCE-AC Document 13 Filed 11/21/22 Page 3 of 4

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NOW THEREFORE, the Parties respectfully request that the Court modify its Order on Joint

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Stipulation to Continue Deadlines in Initial Pretrial Scheduling Order, ECF No. 11, and continue the

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following deadlines:

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Event

Existing Deadline

Requested Deadline

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Deadline to complete all nonexpert discovery

November 21, 2022

December 21, 2022

December 20, 2022

January 20, 2023

January 20, 2023

February 20, 2023

February 21, 2023

March 23, 2023

March 20, 2023

April 19, 2023

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Deadline to complete fact
discovery
Deadline to file dispositive
motions
Deadline to exchange expert
disclosures
Deadline to serve
supplemental list of expert
disclosures

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IT IS SO STIPULATED.
DATE: November ___, 2022

NUNES WORKER RIGHTS LAW, APC

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By:

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Anthony J. Nunes

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Attorneys for Plaintiff
MAURSHAE SMITH

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Dated: November __, 2022

FISHER & PHILLIPS LLP

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By:

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Alden J. Parker
Christopher S. Alvarez

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Attorneys for Defendant
G & B GROCERS dba RANCHO CORDOVA
GROCERY OUTLET [erroneously sued as
G & B GROCERS doing business as
Grocery Outlet]

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JOINT STIPULATION TO CONTINUE DEADLINES IN INITIAL PRETRIAL SCHEDULING ORDER; ORDER
FP 45663345.1

Case 2:21-cv-01504-MCE-AC Document 13 Filed 11/21/22 Page 4 of 4

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ORDER

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Having read and considered the Parties’ Joint Stipulation, for good cause appearing, IT IS

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HEREBY ORDERED as follows:

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1.

Deadline to complete all non-expert discovery: December 21, 2022;

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2.

Deadline to complete fact discovery: January 20, 2023;

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3.

Deadline to file dispositive motions: February 20, 2023;

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4.

Deadline to exchange expert disclosures: March 23, 2023; and

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5.

Deadline to serve supplemental list of expert disclosures: April 19, 2023.

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IT IS SO ORDERED.

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Dated: November 20, 2022

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JOINT STIPULATION TO CONTINUE DEADLINES IN INITIAL PRETRIAL SCHEDULING ORDER; ORDER
FP 45663345.1