Hoeltke v. Quality First Home Improvement, Inc.

Filing 28

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 01/13/2023 EXTENDING the deadline by 30 days. Depositions Completed by 02/13/2023. All Expert Discovery Completed by 2/13/2023. Motion for Class Certification Heard by 4/28/2023. (Rodriguez, E)

Case 2:21-cv-01823-KJM-CKD Document 28 Filed 01/17/23 Page 1 of 3

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M. Anderson Berry (SBN 262879)
CLAYEO C. ARNOLD,
A PROFESSIONAL LAW CORP.
865 Howe Avenue
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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[Additional Counsel Appear on Signature Page]

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Attorneys for Plaintiff and the Proposed Class

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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BRYCE HOELTKE, individually and on behalf
of all others similarly situated,
Plaintiff,

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v.

Case No.: 2:21-cv-01823-KJM-CKD
STIPULATION FOR EXTENSION OF
SCHEDULE; ORDER THEREON

QUALITY FIRST HOME IMPROVEMENT,
INC.,
Defendant.

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IT IS HEREBY STIPULATED by and between Plaintiff Bryce Hoeltke and Defendant

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Quality First Home Improvement, Inc. (collectively, the “Parties”) hereto through the respective

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attorneys that the remaining deadlines in the operative scheduling order in this matter, ECF No.

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26, be extended 30 days. This is the third extension of time requested for this matter. The first was

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an extension of time for Defendant to answer or otherwise respond to Plaintiff’s Complaint, see

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ECF Nos. 8, 9, and the second was a 90-day extension of time to enable the Parties to engage in

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further settlement discussions as well as complete fact witness depositions, expert disclosures and

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discovery, and to file for class certification. ECF Nos. 23, 26. Due to the holidays, the Parties

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STIPULATION FOR EXTENSION OF SCHEDULE; ORDER THEREON – 1
Case No. 2:21-CV-01823-KJM-CKD

Case 2:21-cv-01823-KJM-CKD Document 28 Filed 01/17/23 Page 2 of 3

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encountered delays beyond their control in scheduling depositions and, accordingly, request that

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the following deadlines be extended by 30 days as follows

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Deadline
Depositions Completed by
All Expert Discovery Completed by
Motion for Class Certification Heard by

Doc. No. 26
1/12/2023
1/12/2023
3/16/2023

30-day extension
2/13/2023
2/13/2023
4/17/2023

Good cause exists for the above-proposed extension to allow the Parties to complete
discovery given delays caused by witness availability over the holidays. This short extension will
not prejudice either Party or substantially delay the resolution of this matter.
This document is being electronically filed though the Court’s ECF system. In this regard,
counsel for Plaintiff hereby attests that (1) the content of this Stipulation is acceptable to all persons
required to sign the document; (2) Defendant’s counsel has concurred with the filing of this
Stipulation with her signature below; and (3) a record supporting this concurrence is available for
inspection or production if so ordered.

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Dated: January 13, 2023
By: /s/ Samuel J. Strauss
Samuel J. Strauss (pro hac vice)
Email: [e-mail]
TURKE & STRAUSS LLP
613 Williamson St., Suite 201
Madison, WI 53703
Telephone: [phone]
Facsimile: [phone]
Anthony Paronich (pro hac vice)
Email: [e-mail]
PARONICH LAW, P.C.
350 Lincoln Street, Suite 2400
Hingham, MA 02043
Telephone: [phone]
Facsimile: [phone]

Dated: January 13, 2023
By: /s/ Amy L. Pierce
Amy L. Pierce (SBN 210539)
Email: [e-mail]
LEWIS BRISBOIS BISGAARD &
SMITH LLP
2020 West El Camino Avenue, Ste 700
Sacramento, CA 95833
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant Quality First
Home Improvement, Inc.

M. Anderson Berry (SBN 262879)
Email: [e-mail]
CLAYEO C. ARNOLD,

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STIPULATION FOR EXTENSION OF SCHEDULE; ORDER THEREON – 2
Case No. 2:21-CV-01823-KJM-CKD

Case 2:21-cv-01823-KJM-CKD Document 28 Filed 01/17/23 Page 3 of 3

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A PROFESSIONAL LAW CORP.
865 Howe Avenue
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and the
Proposed Class

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ORDER

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The court extends deadlines as follows:
Deadline
Depositions Completed by
All Expert Discovery Completed by
Motion for Class Certification Heard by

Doc. No. 26
1/12/2023
1/12/2023
3/16/2023

30-day extension
2/13/2023
2/13/2023
4/28/2023

IT IS SO ORDERED.
DATED: January 13, 2023.

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STIPULATION FOR EXTENSION OF SCHEDULE; ORDER THEREON – 3
Case No. 2:21-CV-01823-KJM-CKD