Cook v. Board of Trustees of CSU, et al

Filing 19

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 6/5/2024 EXTENDING the deadline for Non-Expert Discovery to 8/14/2024. (Clemente Licea, O)

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A PROFESSIONAL CORPORATION
Carl L. Fessenden, SBN 161494
David R. Norton, SBN 291448
Larissa C. Celaya, SBN 332882
2180 Harvard Street, Suite 500
Sacramento, CA 95815
TEL: [phone]
FAX: [phone]
EMAIL: [e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants BOARD OF TRUSTEES OF CALIFORNIA STATE UNIVERSITY, (also erroneously sued
as CALIFORNIA STATE UNIVERSITY, SACRAMENTO; and STATE OF CALIFORNIA) and ELVIA RAMIREZ

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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BOOKER COOK, an individual,
Plaintiff,
v.
BOARD OF TRUSTEES OF CALIFORNIA
STATE
UNIVERSITY;
CALIFORNIA
STATE UNIVERSITY, SACRAMENTO;
STATE
OF
CALIFORNIA;
ELVIA
RAMIREZ, an individual; and DOES 1 through
50, inclusive,
Defendants.
______________________________________/

CASE NO.: 2:23-cv-00843-DJC-CKD
JOINT STIPULATION TO MODIFY PRETRIAL SCHEDULING ORDER AND ORDER
Complaint Filed: 10/14/2022
First Amended Complaint Filed: 12/16/2022
Removed: 5/5/2023
Second Amended Complaint Filed: 6/16/2023

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This Stipulation is entered into by and between Plaintiff BOOKER COOK (“Plaintiff”) and

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Defendants BOARD OF TRUSTEES OF CALIFORNIA STATE UNIVERSITY, (also erroneously sued as

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CALIFORNIA STATE UNIVERSITY, SACRAMENTO; and STATE OF CALIFORNIA) and ELVIA

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RAMIREZ (“Defendants”) through their respective counsel of record. The Parties enter into this stipulation

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and proposed order in compliance with the Federal Rule of Civil Procedure 16(b) and the requirements of

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the scheduling order. The parties request to briefly continue the non-expert discovery deadline for 60 days

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solely as it pertains to the deposition of one third-party witness.
{4886-1952-8388}

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JOINT STIPULATION TO MODIFY PRE-TRIAL SCHEDULING ORDER AND ORDER

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WHEREAS, trial is currently set for June 16, 2025;

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WHEREAS, on July 6, 2023, the Court issued a Scheduling Order setting the non-expert discovery

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cut-off date as June 14, 2024;
WHEREAS, the parties have diligently been participating in non-expert discovery, including the
exchange of several sets of written discovery and conducting depositions;

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WHEREAS, the parties intend to complete one additional deposition of third-party witness Dr.

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Boatamo Mosupyoe. However, due to scheduling conflicts between counsel and the witness, the parties are

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unable to complete the deposition prior to the close of discovery;

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WHEREAS, the parties have conferred and propose that the non-expert discovery deadline be

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continued to August 14, 2024 solely as it pertains to the completion of the deposition of Dr. Mosupyoe and

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any related motions arising out of such deposition.

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IT IS SO STIPULATED.

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Dated: June 5, 2024

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PORTER SCOTT
A PROFESSIONAL CORPORATION
By

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/s/ David R. Norton
Carl L. Fessenden
David R. Norton
Larissa C. Celaya
Attorneys for Defendants BOARD OF TRUSTEES
OF CALIFORNIA STATE UNIVERSITY and
ELVIA RAMIREZ

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Dated: June 4, 2024

Law Offices of Johnny L. Griffin, III

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By

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Johnny L. Griffin, III
Manolo Olaso
Attorneys for Plaintiff BOOKER COOK

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{4886-1952-8388}

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JOINT STIPULATION TO MODIFY PRE-TRIAL SCHEDULING ORDER AND ORDER

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ORDER

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PURSUANT TO THE PARTIES’ STIPULATION AND GOOD CAUSE APPEARING, the deadline

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for Non-Expert Discovery is extended to August 14, 2024 solely as it pertains to the completion of the

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deposition of Dr. Boatamo Mosupyoe and any related motions arising out of such deposition.

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IT IS SO ORDERED.

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Dated: June 5, 2024

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/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE

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{4886-1952-8388}

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JOINT STIPULATION TO MODIFY PRE-TRIAL SCHEDULING ORDER AND ORDER