Equal Employment Opportunity Commission v. Lucich

Filing 26

SECOND STIPULATION AND ORDER 25 Requesting Extension of Case Management and Trial Dates: Pretrial Conference set for 8/28/2008 02:00 PM in Courtroom 6, 4th Floor, San Jose. Jury Trial set for 9/15/2008 01:30 PM in Courtroom 6, 4th Floor, San Jose. Motion Hearing set for 7/25/2008 09:00 AM in Courtroom 6, 4th Floor, San Jose. Discovery cutoff 6/13/2008. Signed by Judge Ronald M. Whyte on 2/7/08. (jg, COURT STAFF) (Filed on 2/7/2008)

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Equal Employment Opportunity Commission v. Lucich Doc. 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WILLIAM R. TAMAYO -#084964 (CA) JONATHAN T. PECK - #12303 (VA) SANYA HILL MAXION - #18739 (WA) 350 The Embarcadero, Suite 500 San Francisco District Office San Francisco, California 94105-4000 Telephone: (415) 625-5650 Facsimile: (415) 625-5657 FENN C. HORTON, III, SBN# 119888 ANTHONY J. ADAIR, SBN# 246811 A Professional Corporation 225 West Santa Clara Street, Suite 1500 San Jose, CA 95113-1752 Telephone: (408) 286-5100 Facsimile: (408) 286-5722 *E-FILED - 2/7/08* UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff(s), vs. SLADANA LUCICH, d/b/a WHITE OAKS AUTO BODY, Defendant(s). ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: C-07-00507 RMW SECOND STIPULATION AND [] ORDER REQUESTING EXTENSION OF CASE MANAGEMENT AND TRIAL DATES STIPULATION Plaintiff EEOC and Defendant White Oaks Auto Body Inc., through their counsel of record, hereby stipulate as follows: WHEREAS, the parties agreed to a tentative settlement at a mediation session on July 31, 2007 which was contingent upon Plaintiff EEOC receiving certain financial records from 0-1 Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Defendant by August 21, 2007 to confirm Defendant's financial condition and to allow sufficient time for the EEOC's expert at EEOC Headquarters to inspect and analyze said records; WHEREAS, at the July 31st mediation, the parties also agreed to vacate the existing noticed depositions and discovery for purposes of efficiency and economy and in order to attempt good faith settlement negotiations; WHEREAS, since July 31, 2007, the parties have engaged in numerous conference calls to discuss the records requests and to engage in further settlement negotiations and have exchanged numerous documents and correspondence. WHEREAS, the parties have agreed to schedule another conference call to be held before the end of January 2008 to continue the settlement negotiations. 15 16 17 18 19 20 21 22 23 24 25 WHEREAS, on November 26, 2007, this Court granted the parties' First Stipulation and Proposed Order Requesting Extension of Case Management and Trial Dates; WHEREAS, the parties expect to continue to engage in good faith settlement negotiation during the ensuing months and the parties recognize that more time is needed in order effectively settle this matter; 0-2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WHEREAS, the parties would like to avoid the expense and inconvenience of concurrently taking depositions or conducting other discovery or trial at the same time the parties are attempting to settle this case in good faith; WHEREAS, the current Case Management and Trial dates are as follows: Deadline for Joinder of Any Additional Parties/Amendment of Pleadings Plaintiff's Designation of Experts Reports Defendant's Designation of Rebuttal Experts with Reports Fact Discovery Cutoff Expert Discovery Cutoff Last Day for Dispositive Motion Hearing Final Pretrial Conference Trial January 29, 2008 March 21, 2008 April 11, 2008 April 11, 2008 April 25, 2008 May 30, 2008 9:00 a.m. June 23, 2008 2:00 p.m. July 14, 2008 1:30 p.m. THEREFORE, Plaintiff EEOC and Defendant White Oaks Auto Body, Inc, through their counsel of record, hereby respectfully request this Court to extend the Case Management 0-3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and Trial Dates approximately sixty (60) more days as follows to allow the parties to negotiate a settlement in good faith: Deadline for Joinder of Any Additional Parties/Amendment of Pleadings Plaintiff's Designation of Experts Reports Defendant's Designation of Rebuttal Experts with Reports Fact Discovery Cutoff Expert Discovery Cutoff Last Day for Dispositive Motion Hearing Final Pretrial Conference Trial March 25, 2008 March 23, 2008 June 13, 2008 June 13, 2008 June 27, 2008 July 25, 2008 9:00 a.m. August 28, 2008 2:00 p.m. September 15, 2008 1:30 p.m. Dated: ______1/8/08__ _s/ Sanya Hill-Maxion_______ Attorney for Plaintiff EQUAL EMPLOYMENT OPPORTUNITY COMMISSION _s/ A.J. Adair______________ Attorney for Defendant WHITE OAKS AUTO BODY, INC. Dated: _ _____1/8/08___ 0-4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ORDER Pursuant to the Stipulation above, the Case Management and Trial Dates are to be extended as follows: Deadline for Joinder of Any Additional Parties/Amendment of Pleadings Plaintiff's Designation of Experts Reports Defendant's Designation of Rebuttal Experts with Reports Fact Discovery Cutoff Expert Discovery Cutoff Last Day for Dispositive Motion Hearing Final Pretrial Conference Trial March 25, 2008 March 23, 2008 June 13, 2008 June 13, 2008 June 27, 2008 July 25, 2008 9:00 a.m. August 28, 2008 2:00 p.m. September 15, 2008 1:30 p.m. IT IS SO ORDERED. Dated: 2/7/08 _____________ ______________________________ Honorable Ronald M. Whyte UNITED STATES DISTRICT JUDGE 0-5

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