Ambrosini v. Universal Cable Holdings, Inc. dba Suddenlink Communications et al

Filing 38

STIPULATION AND ORDER FOR LIMITED MODIFICATION TO SCHEDULING ORDER. Signed by Judge Richard Seeborg on 1/28/15. (cl, COURT STAFF) (Filed on 1/28/2015)

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Bradford C. Floyd (SBN 136459)
Carlton D. Floyd (SBN 275958)
LAW OFFICE OF BRADFORD C. FLOYD
819 Seventh Street
Eureka, California 95501
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail]

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Attorneys for Plaintiff KEITH AMBROSINI
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SEYFARTH SHAW LLP
Laura Wilson Shelby (SBN 151870)
[e-mail]
2029 Century Park East, Suite 3500
Los Angeles, California 90067-3021
Telephone:
[phone]
Facsimile:
[phone]
SEYFARTH SHAW LLP
Coby M. Turner (SBN 266298)
[e-mail]
400 Capitol Mall, Suite 2350
Sacramento, California 95814-4428
Telephone:
[phone]
Facsimile:
[phone]
SEYFARTH SHAW LLP
Nicholas R. Clements (SBN 267314)
[e-mail]
560 Mission Street, Suite 3100
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
UNIVERSAL CABLE HOLDINGS, INC., dba
SUDDENLINK COMMUNICATIONS
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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KEITH AMBROSINI,

Case No. 3:14-cv-00896-RS

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Plaintiff,
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v.
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STIPULATION AND [PROPOSED]
ORDER FOR LIMITED
MODIFICATION TO SCHEDULING
ORDER

UNIVERSAL CABLE HOLDINGS, INC.,
DBA SUDDENLINK COMMUNICATIONS,
and DOES 1 through 100, inclusive,

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Defendants.
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STIPULATION TO MODIFY SCHEDULING ORDER AND [PROPOSED] ORDER
18896725v.1

/ CASE NO. 3:14-CV-00334-VC

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Pursuant to Local Rule 6-1(b), Plaintiff KEITH AMBROSINI (“Plaintiff”), on the one

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hand, and Defendants UNIVERSAL CABLE HOLDINGS, INC., dba SUDDENLINK

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COMMUNICATIONS, (“Defendant”), by and through their undersigned counsel, hereby

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stipulate as follows:

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WHEREAS, the Court entered a Case Management Scheduling Order on May 29, 2014
(the “Scheduling Order”). (Dkt. 24.)

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WHEREAS the Scheduling Order requires discovery to be completed on or before
January 30, 2015.

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WHEREAS, Plaintiff requires additional time to take the depositions of two witnesses,

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Aaron Byer and Casey Kelly, due to the unavailability of these witnesses until February 20,

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2015.

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WHEREAS, dispositive motions in this case are to have been completed and filed by

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February 12, 2015, with hearing dates scheduled for no later than March 19, 2015. However,

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given Plaintiff’s need to extend the discovery deadline as to the above-mentioned witnesses, the

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dispositive motions and hearing deadlines will also need to be continued. The Parties, therefore,

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seek a 21-day extension to complete and file their pre-trial dispositive motions, if any, until

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March 5, 2015. The pre-trial dispositive hearing deadline will consequently also require

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continuation, until April 9, 2015.

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WHEREAS, the additional time the Parties seek will not alter the current trial date set for
June 8, 2015.

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IT IS THEREFORE STIPULATED that:

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1.

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The deadline to complete Plaintiff’s depositions of witnesses Aaron Byer and

Casey Kelly will be continued until February 20, 2015.
2.

The deadline to complete and file any pre-trial dispositive motions will be

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continued from February 12, 2015 until March 5, 2015. The hearing dates for any pre-trial

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dispositive motions will be continued from March 19, 2015 until April 9, 2015.

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IT IS SO STIPULATED.

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STIPULATION TO MODIFY SCHEDULING ORDER AND [PROPOSED] ORDER / CASE NO. 3:14-CV-00334-VC
18896725v.1

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DATED: January 28, 2015

SEYFARTH SHAW LLP

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By:

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Attorneys for Defendant
UNIVERSAL CABLE HOLDINGS, INC., dba
SUDDENLINK COMMUNICATIONS

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/s/ Nicholas R. Clements
Laura Wilson Shelby
Coby M. Turner
Nicholas R. Clements

DATED: January 28, 2015

LAW OFFICE OF BRADFORD C. FLOYD

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By:

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/s/ Bradford C. Floyd
Bradford C. Floyd
Carlton D. Floyd

Attorneys for Plaintiff
KEITH AMBROSINI

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STIPULATION TO MODIFY SCHEDULING ORDER AND [PROPOSED] ORDER / CASE NO. 3:14-CV-00334-VC
18896725v.1

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
1.

The deadline to complete Plaintiff’s depositions of witnesses Aaron Byer and

Casey Kelly will be continued until February 20, 2015.
2.

The deadline to complete and file any pretrial dispositive motions will be

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continued from February 12, 2015 until March 5, 2015. The hearing dates for any pre-trial

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dispositive motions will be continued from March 19, 2015 until April 9, 2015.

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DATED: _________________
1/28/2015

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_____________________________
HON. RICHARD SEEBORG
United States District Court Judge

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STIPULATION TO MODIFY SCHEDULING ORDER AND [PROPOSED] ORDER / CASE NO. 3:14-CV-00334-VC
18896725v.1