Bernal v. America Reprographics Company, LLC

Filing 23

AMENDED Order on Motion to Continue, Order on Motion for Extension of Time to Complete Discovery. Signed by Judge Kandis A. Westmore on August 15, 2013. (kawlc2, COURT STAFF) (Filed on 8/15/2013)

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PATRICK R. CO, ESQ. BAR #: 200160
THE CO LAW FIRM, A PROFESSIONAL CORPORATION
201 Spear Street, Suite 1100
San Francisco, CA 94105
[phone] [phone] FAX
Attorneys for Plaintiff,
ANSELMO BERNAL

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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ANSELMO BERNAL,

CASE NO.: C 13-0750 KAW

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Plaintiff,
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v.
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STIPULATED MOTION TO MODIFY
SCHEDULING ORDER, PROPOSED
ORDER, AND DECLARATION OF
COUNSEL

AMERICAN REPROGRAPHICS
COMPANY, et al.; and DOES 1 - 20,
Defendants.

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C:\CoLawFirm\Clients\0200\03121\Trial Continuance\trialcontinuance.stip.wpd

STIPULATED MOTION TO MODIFY SCHEDULING ORDER, PROPOSED ORDER, AND
DECLARATION OF COUNSEL

STIPULATED MOTION

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On May 24, 2013, the Court entered its Case Management and Pretrial Order for Jury Trial

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(“CASE MANAGEMENT SCHEDULING ORDER,” ECF No. 15) in the above captioned action.

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Discovery has commenced in this action. Plaintiff has served interrogatories, requests for production,

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and requests for admissions. The plaintiff and defendant are meeting and conferring to resolve

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discovery disputes that have arisen. The following depositions are currently scheduled:

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Deponent

Scheduled Date

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ARC employee Janine Sperry

August 16, 2013

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Plaintiff Anselmo Bernal

August 21, 2013

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ARC employee Soren Goodman

September 6, 2013

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ARC employee Voltaire “Butch” Balancio

TBD

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Plaintiff anticipates that he will have insufficient time to complete discovery by the September

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30, 3013 discovery cut-off date. In order to foster efficiency, the parties have agreed to request

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that the Court modify the deadlines imposed by the current Case Management Scheduling

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Order.

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Specifically, the parties, by and through their respective counsel, move the court to amend the

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Case Management Scheduling Order as set forth in the following table:

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EVENT

SCHEDULING ORDER

PROPOSED SCHEDULE

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Trial

January 21, 2014

May 27, 2014

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Pretrial Conference

January 7, 2014

May 12, 2014

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Objections

December 30, 2013

May 5, 2014

Joint Pretrial Statement

December 20, 2013

April 25, 2014

Meet and Confer

December 10, 2013

April 15, 2014

Last Day to hear Dispositive

November 7, 2013

March 13, 2014

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Motions

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Close of Fact and Expert Discovery

September 30, 2013

February 3, 2014

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Rebuttal Expert Disclosure

September 16, 2013

January 21, 2014

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Expert Disclosure

September 2, 2013

January 6, 2014

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C:\CoLawFirm\Clients\0200\03121\Trial Continuance\trialcontinuance.stip.wpd

STIPULATED MOTION TO MODIFY SCHEDULING ORDER, PROPOSED ORDER, AND
DECLARATION OF COUNSEL

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The proposed modifications do not change the current times between events, and do not reduce

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Accordingly, plaintiff Anselmo Bernal and Defendant ARC Document Solutions, Inc., by and

5 through their respective undersigned counsel, respectfully request that the Court enter an order
6 modifying the schedule as set forth above.
7 Dated: August 14, 2013

JACKSON LEWIS LLP

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/S/
Conor J. Dale
Attorneys for Defendant,
ARC DOCUMENT SOLUTIONS, INC.
By:

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THE CO LAW FIRM

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By:

/S/
Patrick R. Co
Attorney for Plaintiff,
ANSELMO BERNAL

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[proposed] ORDER
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PURSUANT TO STIPULATION OF THE PARTIES IT IS SO ORDERED.
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August 15
Dated:_______________, 2013

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_______________________________________
KANDIS A. WESTMORE
UNITED STATES MAGISTRATE JUDGE

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C:\CoLawFirm\Clients\0200\03121\Trial Continuance\trialcontinuance.stip.wpd

STIPULATED MOTION TO MODIFY SCHEDULING ORDER, PROPOSED ORDER, AND
DECLARATION OF COUNSEL

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