Equal Employment Opportunity Commision v. Walgreen Co.

Filing 54

ORDER re 53 STIPULATION WITH PROPOSED ORDER TO EXTEND DEADLINES. Discovery cutof: 12/6/2013. Motions to be heard by 3/5/2014. Further Case Management Conference remains set for 1/14/2014 02:00 PM in Courtroom 2, 17th Floor, San Francisco. Pretrial Conference set for 5/19/2014 02:00 PM and Jury Trial set for 6/2/2014 08:30 AM in Courtroom 12, 19th Floor, San Francisco before Hon. William H. Orrick. Signed by Judge William H. Orrick on 10/22/2013. (jmdS, COURT STAFF) (Filed on 10/22/2013)

1
2
3

Alden J. Parker, State Bar No. 196808
Scott M. Plamondon, State Bar No. 212294
Shauna N. Correia, State Bar No. 232410
weintraub tobin chediak coleman grodin
LAW CORPORATION

5

400 Capitol Mall, 11th Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile:
916/446.1611

6

Attorneys for WALGREEN CO.

4

7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

11
12

EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,

13

) Case No. C-11-4470 WHO
)
) STIPULATION AND REQUEST TO
) EXTEND DEADLINES AND ORDER
)
)
)
)
)
)
)
)
)

Plaintiff,

14

v.

15
law corporation

weintraub tobin chediak coleman grodin

10

WALGREEN CO.,

16

Defendants.

17
18

STIPULATION AND REQUEST

19
20
21

The parties to this matter, by and through their counsel of record, hereby stipulate
as follows:

22

Whereas the United States Equal Employment Opportunity Commission

23

(“Commission”), Plaintiff in this case, has reopened after a sixteen-day government

24

shutdown, the parties agree and request of the Court that any dates presently set in this

25

case, including but not limited to discovery dates and scheduled depositions, should be

26

extended for approximately thirty (30) days from the previous set deadlines pursuant to

27

the following proposed dates:

28
{1691653.DOC;}

1

Stipulation and Order to Extend Deadlines

1
2

Event

Previous Deadline

Proposed Deadline

3

Discovery Cut-Off
Expert Disclosures
Dispositive Motions
Filing
Rebuttal Expert
Disclosures
Expert Discovery CutOff
Further Case
Management
Conference
Hearing on Dispositive
Motions
Pre-Trial Conference
Statement Deadline
Pre-Trial Conference
Trial

October 25, 2013
November 29, 2013
December 6, 2013

December 6, 2013
January 10, 2014
January 24, 2014

December 13, 2013

January 17, 2014

December 27, 2013

January 31, 2014

January 14, 2014

February 18, 2014

January 15, 2014

February 28, 2014

April 1, 2014

May 6, 2014

April 14, 2014
April 28, 2014

May 19, 2014
June 2, 2014

4
5
6
7
8
9

11
12
13
14
15
law corporation

weintraub tobin chediak coleman grodin

10

16

The parties further stipulate that these dates reflect current scheduling difficulties

17

regarding depositions of Charging Party’s physician, Dr. Juanito Austria, and former Store

18

Manager, Kathy Marsh. Dr. Austria’s deposition, which was previously set for October 10,

19

2013, was cancelled due to the government shutdown.

20

ended, Dr. Austria is currently unavailable as he is out of the country and will not return

21

until late November. His deposition is necessary to Defendant’s motion for summary

22

judgment and therefore, the summary judgment motion filing deadline must be moved

23

to allow for the completion of Dr. Austria’s deposition to take place. Additionally, Kathy

24

Marsh is currently unavailable to be deposed as she is on medical leave.

25

reasons stated above, we request that all dates be extended for approximately thirty days.

Although the shutdown has

For these

26
27

Dated: October 22, 2013

28
{1691653.DOC;}

EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION
2

Stipulation and Order to Extend Deadlines

By:

1
2

/S/ Peter Laura
PETER LAURA
Attorneys for Plaintiff

3
4

Dated: October 22, 2013

WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN

Law Corporation

5
6

By:

7
8

s/ Scott M. Plamondon
SCOTT M. PLAMONDON
SHAUNA N. CORREIA
Attorneys for Defendant WALGREEN CO

9
ORDER

11
12
13
14
15
law corporation

weintraub tobin chediak coleman grodin

10

16
17
18
19

Pursuant to the stipulation and request of the parties,
IT IS SO ORDERED with the following modifications.

First, the next Case

Management Conference shall remain as scheduled on January 14, 2014. Second,
the last day for hearing dispositive motions shall be March 5, 2014.

All other

proposed dates are acceptable.
Dated: October 22, 2013

____________________________________

20

U.S. District Court Judge

21
22

23
24
25
26
27
28
{1691653.DOC;}

3

Stipulation and Order to Extend Deadlines