Perry v. Perdue Foods LLC et al

Filing 52

STIPULATION AND ORDER re 51 STIPULATION WITH PROPOSED ORDER Revised Joint Stipulation to Conduct Deposition of Ryan Jacobson after Discovery Cut-off Deadline filed by Barbara Perry. Signed by Judge Jon S. Tigar on November 13, 2018. (wsn, COURT STAFF) (Filed on 11/13/2018)

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HUNTER PYLE, SBN 191125
TANYA P. TAMBLING, SBN 262979
HUNTER PYLE LAW
428 Thirteenth Street, 11th Floor
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
[e-mail], ttambling@hunterpylelaw..com

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Attorneys for Plaintiff
BARBARA PERRY

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[Additional Counsel on the Next Page]

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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BARBARA PERRY,

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Plaintiff,

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CASE NO.:

vs.

JOINT STIPULATION AND
[PROPOSED] ORDER TO CONDUCT
THE DEPOSITION OF RYAN
JACOBSON AFTER THE
DISCOVERY CUT-OFF

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3:17-cv-03502-JST
18-cv-02664-JST

Complaint filed: June 16, 2017
Trial date:
June 10, 2019

PERDUE FOODS, LLC and COLEMAN
NATURAL FOODS, LLC,
Defendants.

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PERRY v. PERDUE FOODS, LLC, et al.
JOINT STIPULATION AND [PROPOSED] ORDER TO CONDUCT THE DEPOSITION OF RYAN JACOBSON
AFTER THE DISCOVERY CUT-OFF

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ALEX G. TOVARIAN, SBN 264547
LAW OFFICES OF ALEKSEY G. TOVARIAN
50 California Street, Ste. 3325
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Plaintiff
BARBARA PERRY
MICHAEL A. HOOD, SBN 71258
ERIN W. KENDRELLA, SBN 273504
JACKSON LEWIS P.C.
200 Spectrum Center Drive, Ste. 500
Irvine, CA 92618
Telephone: [phone]
Facsimile: [phone]
[e-mail], [e-mail]
Attorneys for Defendant
PERDUE FOODS LLC dba Coleman Natural Foods
(erroneously sued as Coleman Natural Foods, LLC)

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PERRY v. PERDUE FOODS, LLC, et al.
JOINT STIPULATION AND [PROPOSED] ORDER TO CONDUCT THE DEPOSITION OF RYAN JACOBSON
AFTER THE DISCOVERY CUT-OFF

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Plaintiff BARBARA PERRY (“Plaintiff”) and Defendant PERDUE FOODS LLC

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dba Coleman Natural Foods (erroneously sued as Coleman Natural Foods, LLC)

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(“Defendant”), by and through their counsel of record, hereby jointly stipulate that the

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deposition of Ryan Jacobson may be conducted after the December 14, 2018, discovery

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cut-off, due to his unavailability.

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On October 25, 2018, defense counsel spoke with Ryan Jacobson about the

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possibility of his deposition. At this time, Mr. Jacobson informed defense counsel that he

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currently resides in Portland, Oregon. Mr. Jacobson further informed defense counsel

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that he would make himself available for his deposition the week of December 10, 2018.

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Therefore, the Parties agreed and stipulated to conducting his deposition on December

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12, 2018. (See Docket Number 48: Joint Stipulation and Order for Deposition Schedule

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and 30(b)(6) Topics.)

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However, on November 9, 2018, defense counsel spoke again with Mr. Jacobson

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and he explained that he was not available for his deposition the week of December 10,

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2018, because of a family obligation. Furthermore, Mr. Jacobson conveyed that it would

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be very difficult to schedule time for his deposition anytime between now and December

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14, 2018, because he has previously scheduled work trips to Ohio and Los Angeles, along

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with the Thanksgiving holiday during this time. Therefore, Mr. Jacobson requested for

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his deposition to be conducted after January 1, 2019, on a mutually agreeable date for

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him and the Parties.
As Mr. Jacobson is unavailable prior to the December 14, 2018, discovery cut-off,

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the Parties agree and stipulate that Mr. Jacobson’s deposition may be conducted after

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December 14, 2018. The parties further agree that Mr. Jacobson’s deposition subpoena

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may be served on defense counsel by email.

ERED

O ORD
IT IS S

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UNIT
ED

Dated: November 13, 2018

S DISTRICT
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PERRY v. PERDUE FOODS, LLC, et al.
n S. Tig
Judge Jo
JOINT STIPULATION AND [PROPOSED] ORDER TO CONDUCT THE DEPOSITION OF RYAN JACOBSON
ER
AFTER THE DISCOVERY CUT-OFF
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F
D IS T IC T O
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED: November 13, 2018

/s/
Tanya Tambling
Attorney for Plaintiff

DATED: November 13, 2018

/s/
Erin Kendrella
Attorney for Defendant

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IT IS SO ORDERED.

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Dated:

__________________________
Hon. Jon S. Tigar
United States District Judge

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PERRY v. PERDUE FOODS, LLC, et al.
JOINT STIPULATION AND [PROPOSED] ORDER TO CONDUCT THE DEPOSITION OF RYAN JACOBSON
AFTER THE DISCOVERY CUT-OFF

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