Daughton v. Amazon.com Services LLC

Filing 14

STIPULATION and ORDER signed by Senior District Judge Kimberly J. Mueller on 09/24/2024 MODIFYING the Pretrial Scheduling Order as follows: Initial Expert Disclosure due 05/15/2025; Rebuttal Expert Disclosure due 06/06/2025; Fact Discovery Cut-Off 07/10/2025; Expert Discovery Cut-Off 07/10/2025; Dispositive Motions due 10/10/2025. (Lopez, K)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

MAKAREM & ASSOCIATES
Aidan McGlaze, Bar No. 277270
[e-mail]
11601 Wilshire Blvd, Suite 2440
Los Angeles, CA 90025
Tel: [phone]
Fax: [phone]
Attorney for Plaintiff
LISA DAUGHTON
MORGAN, LEWIS & BOCKIUS LLP
Brian D. Fahy, Bar No. 266750
[e-mail]
300 South Grand Avenue
Twenty-Second Floor
Los Angeles, CA 90071-3132
Tel: [phone]
Fax: [phone]
MORGAN, LEWIS & BOCKIUS LLP
Ryan S. Malhan, Bar No. 352467
[e-mail]
One Market, Spear Street Tower
San Francisco, CA 94105-1596
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
AMAZON.COM SERVICES LLC

17

UNITED STATES DISTRICT COURT

18

EASTERN DISTRICT OF CALIFORNIA

19
20
21
22
23
24
25
26

LISA DAUGHTON, an individual,
Plaintiff,
vs.
AMAZON.COM SERVICES, LLC, a
Delaware corporation; and DOES 1-10,
inclusive,

Case No. 2:23-cv-02977-KJM-CKD
JOINT STIPULATION TO CONTINUE
CERTAIN CASE DEADLINES AND
ORDER
LOCAL RULE 144

Defendant.

27
28
MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
LOS ANGELES

JOINT STIPULATION TO CONTINUE
CERTAIN CASE DEADLINES
2:23-CV-02977-KJM-CKD

1
2

Amazon.com Services LLC (“Amazon”) (Plaintiff and Defendant collectively, the “Parties”)

4

jointly stipulate to a request that the Court continue by up to 6 months the existing expert

5

discovery, fact discovery, and dispositive motion deadlines, based upon the following good cause:
WHEREAS, the Parties have been diligently engaged in discovery, including providing

7

initial and supplemental disclosures, written discovery, production of documents, and are

8

currently meeting and conferring on depositions of Plaintiff and Amazon employees;

9
10
11

WHEREAS, the Parties have also had preliminary discussions regarding potential
informal resolution;
WHEREAS, counsel for Plaintiff recently assumed responsibility for this matter from

12

another attorney in his office and has requested a 6-month extension of the expert and fact

13

discovery deadlines to allow him time to get up speed on this matter and assess next steps in

14

discovery, which will aid in the Parties’ discussions on potential informal resolution;

15

WHEREAS, counsel for Amazon is agreeable to the requested extension and believes

16

extending the dispositive motion deadline by six months would also be warranted if the expert

17

and fact discovery deadlines are continued; and

18
19
20

WHEREAS, this is the Parties’ first request for a continuance of the pretrial dates in this
matter; and
WHEREAS, while the Parties are requesting a six-month continuance of certain deadlines,

21

if the Court is not amenable to an extension of that length, they would request an extension of at

22

least four months of the deadlines noted below, for the reasons noted above.

23
24
25
26
27
28
MORGAN, LEWIS &
BOCKIUS LLP
LOS ANGELES

Pursuant to Local Rule 144, Plaintiff Lisa Daughton (“Plaintiff”) and Defendant

3

6

ATTORNEYS AT LAW

JOINT STIPULATION

THEREFORE, the Parties respectfully request that the Court make the following
modifications to the Pretrial Scheduling Order:
Event

Current Date

Proposed Date

Initial Expert Disclosure

November 15, 2024

May 15, 2025

Rebuttal Expert Disclosure

December 6, 2024

June 6, 2025

2

JOINT STIPULATION TO CONTINUE
CERTAIN CASE DEADLINES
2:23-CV-02977-KJM-CKD

1
2
3
4
5

Fact Discovery Cut-Off

January 10, 2025

July 10, 2025

Expert Discovery Cut-Off

January 10, 2025

July 10, 2025

L/D to File Dispositive Motions

April 10, 2025

October 10, 2025

Dated: September 24, 2024

MAKAREM & ASSOCIATES

6

By

/s/ Aidan McGlaze
Aidan McGlaze
Attorney for Plaintiff
LISA DAUGHTON
MORGAN, LEWIS & BOCKIUS LLP

7
8

Dated: September 24, 2024

9
By

10
11
12

SIGNATURE ATTESTATION

13
14
15
16

/s/ Brian D. Fahy
Brian D. Fahy
Ryan S. Malhan
Attorneys for Defendant
AMAZON.COM SERVICES LLC

I hereby attest that all signatories listed above, on whose behalf this stipulation is
submitted, concur in the filing’s content and have authorized the filing.
Dated: September 24, 2024

MORGAN, LEWIS & BOCKIUS LLP

17

By

18
19

/s/ Brian D. Fahy
Brian D. Fahy
Ryan S. Malhan
Attorneys for Defendant
AMAZON.COM SERVICES LLC

20
21
22
23
24
25
26
27
28
MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
LOS ANGELES

3

JOINT STIPULATION TO CONTINUE
CERTAIN CASE DEADLINES
2:23-CV-02977-KJM-CKD

1
2

ORDER
Based upon the Parties’ Joint Stipulation to Extend Case Deadlines, and for good cause

3

having been shown, the Current Pretrial Scheduling Order at ECF No. 10 is modified as

4

requested by the parties above.

5

IT IS SO ORDERED.

6
7

Dated: September 24, 2024

8
UNITED STATES DISTRICT JUDGE

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
LOS ANGELES

4

JOINT STIPULATION TO CONTINUE
CERTAIN CASE DEADLINES
2:23-CV-02977-KJM-CKD