Cafe v. Prime Now LLC et al

Filing 14

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 5/10/2024 MODIFYING The Pretrial Scheduling Order as follows: Non-expert discovery completion date 11/19/2024. Expert witness disclosure deadline 1/17/2025. Supplemental expert witness disclosure deadline 2/18/2025. Supplemental discovery completion date 4/18/2025. Dispositive motion deadline 5/19/2025. (Mena-Sanchez, L)

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Ramin R. Younessi, Bar No. 175020
[e-mail]
Samantha L. Ortiz, Bar No. 312503
[e-mail]
Christopher S. Afgani, Bar No. 336750
[e-mail]
LAW OFFICES OF RAMIN R. YOUNESSI
A PROFESSIONAL LAW CORPORATION
3435 Wilshire Blvd. Suite 2200
Los Angeles, CA 90010
Telephone: [phone]
Facsimile:
213.480.6201
Attorneys for Plaintiff
SHEILA ROWELA CAFE
Britney N. Torres, Bar No. 287019
[e-mail]
Douglas L. Ropel, Bar No. 300486
[e-mail]
LITTLER MENDELSON, P.C.
500 Capitol Mall, Suite 2000
Sacramento, California 95814
Telephone:
916.830.7200
Fax No.:
916.561.0828
Attorneys for Defendants
PRIME NOW LLC and AMAZON.COM
SERVICES LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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SHEILA ROWELA CAFE, an individual,

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Plaintiff,

Case No. 2:23-cv-02867-TLN-KJN
JOINT STIPULATION TO MODIFY
SCHEDULING ORDER; ORDER

v.
PRIME NOW LLC, a limited liability company;
AMAZON.COM SERVICES, LLC, a limited
liability company; and DOES 1 through 20,
inclusive,
Defendants.

Trial Date:
Complaint Filed:

Not Yet Set
October 30, 2023

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JOINT STIPULATION TO MODIFY SCHEDULING
ORDER; ORDER

Case No. 2:23-CV-02867-TLN-KJN

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Plaintiff SHEILA ROWELA CAFE (“Plaintiff”) and Defendants PRIME NOW LLC and

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AMAZON.COM SERVICES LLC (“Defendants”) (collectively Plaintiff and Defendants are referred

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to herein as the “Parties”), by and through their respective counsel of record, hereby stipulate to

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continue the deadlines set by the Initial Pretrial Scheduling Order (ECF Dkt. 3).

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WHEREAS, Plaintiff filed the operative Complaint on October 30, 2023, in the
Superior Court of California, County of Sacramento;

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WHEREAS, Defendants removed this matter to the United States District Court,
Eastern District of California on December 7, 2023;

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WHEREAS, on December 8, 2023, the Court issued an Initial Pretrial Scheduling
Order that set forth the following litigation dates:

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Non-expert discovery completion date – August 5, 2024 (240 days after removal);

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Expert witness disclosure deadline – October 4, 2024 (60 days after close of

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discovery);
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initial expert witness disclosures);
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Supplemental expert witness disclosure deadline – November 4, 2024 (30 days after

Supplemental discovery completion date – January 2, 2025 (30 days prior to the
dispositive motion deadline); and

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Dispositive motion deadline – February 1, 2025 (180 days after close of discovery);

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WHEREAS, the Parties have agreed to participate in a private mediation currently

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scheduled to be held on August 19, 2024, and the Parties seek to stay litigation activities in order to

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focus their efforts on potential resolution of this matter;

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WHEREAS, the Parties respectfully request that the Court modify the Initial Pretrial
Scheduling Order and reset the litigation dates as follows (or other dates as the Court sees fit);

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Non-expert discovery completion date – November 19, 2024;

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Expert witness disclosure deadline – January 17, 2025;

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Supplemental expert witness disclosure deadline – February 17, 2025;

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Supplemental discovery completion date – April 18, 2025; and

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-

Dispositive motion deadline – May 19, 2025.

JOINT STIPULATION TO MODIFY SCHEDULING
ORDER; ORDER

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Case No. 2:23-CV-02867-TLN-KJN

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Dated: May 10, 2024

LAW OFFICES OF RAMIN R. YOUNESSI, APC

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/s/ Chris S. Afgani (as authorized on 5/9/24)
Ramin R. Younessi
Samantha L. Ortiz
Christopher S. Afgani

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Attorneys for Plaintiff
SHEILA ROWELA CAFE

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Dated: May 10, 2024

LITTLER MENDELSON, P.C.

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/s/ Douglas L. Ropel
Britney N. Torres
Douglas L. Ropel

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Attorneys for Defendants
PRIME NOW LLC and AMAZON.COM
SERVICES LLC

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ORDER

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AS STIPULATED, the Pretrial Scheduling Order is modified as follows:

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Non-expert discovery completion date – November 19, 2024;

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Expert witness disclosure deadline – January 17, 2025;

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Supplemental expert witness disclosure deadline – February 18, 2025;

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Supplemental discovery completion date – April 18, 2025; and

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Dispositive motion deadline – May 19, 2025.

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IT IS SO ORDERED.

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DATED: May 10, 2024

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Troy L. Nunley
United States District Judge

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JOINT STIPULATION TO MODIFY SCHEDULING
ORDER; ORDER

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Case No. 2:23-CV-02867-TLN-KJN