United States Equal Employment Opportunity Commission v. Giumarra Vineyards Corporation
Filing
41
STIPULATION and ORDER to Extend Deadlines signed by Judge Oliver W. Wanger on 6/27/2011. The Settlement Conference currently scheduled for 7/1/2011 has been VACATED. (Discovery due by 9/30/2011; Dispositive Motions filed by 9/30/2011; Expert Disclosure due by 10/30/2011; Expert Discovery Deadline: 11/30/2011; Jury Trial set for 1/31/2012 at 09:00 AM in Courtroom 3 (OWW) before Judge Oliver W. Wanger) (Figueroa, O)
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1 JEFFREY S. RANEN, SB# 224285
E-Mail: ranen@lbbslaw.com
2 NATHALIE ADOURIAN, SB# 274599
E-Mail : nadourian@lbbslaw.com
3 LEWIS BRISBOIS BISGAARD & SMITH LLP
221 North Figueroa Street, Suite 1200
4 Los Angeles, California 90012
Telephone: 213.250.1800
5 Facsimile: 213.250.7900
6 Attorneys for Defendant GIUMARRA VINEYARDS CORPORATION
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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Equal Employment Opportunity Commission,
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Plaintiff,
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v.
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Delfina Ochoa, Maribel Ochoa, Jose Ochoa,
15 and Guadalupe Martinez,
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Plaintiffs/Intervenors.
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v.
19 Giumarra Vineyards Corporation,
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Defendants.
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CASE NO. 1:09-CV-02255-OWW-SMS
STIPULATION AND ORDER TO
EXTEND DEADLINES
The Honorable Michael J. Seng
U.S. Magistrate Judge
ACTION FILED:
TRIAL DATE:
2/9/10
11/15/11
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TO THE HONORABLE COURT AND TO ALL PARTIES OF AND COUNSEL OF
22
23 RECORD:
Plaintiff-Intervenors and Defendant have a scheduled mediation for August 25, 2011
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25 before private mediator Carla Barboza. As such, all parties agree that the Settlement Conference
26 scheduled for July 1, 2011 is unnecessary and stipulate that it be taken off calendar.
27 / / /
LEWI
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BRISBOI
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BISGAAR
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4823-6232-4745.1
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES
1
Likewise, the parties anticipate taking additional discovery prior to the August 25, 2011
2 mediation in order for the mediation to be more productive, and stipulate that the current deadlines
3 be extended to accommodate adequately preparing the matter.
4
In good faith and by agreement of the parties, through counsel undersigned, it is
5 respectfully requested that a revised scheduling order be entered to reflect the following stipulated
6 deadlines:
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1.
The deadline for completing discovery shall be September 30, 2011;
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2.
The deadline for filing dispositive motions shall be September 30, 2011;
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3.
The expert disclosure deadline shall be October 30, 2011;
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4.
The expert discovery deadline shall be November 30, 2011; and
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5.
The trial start date be continued to January 31, 2012.
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These deadlines shall not be amended without further Order of the Court.
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This stipulation and the proposed order are submitted in good faith and not for the purpose
14 of delay.
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This Stipulation may be signed in counter-parts, each counter-part having the same force
16 and effect as originals, and facsimile signatures shall be deemed to have the same force as
17 originals.
18 IT IS SO STIPULATED.
19 DATED: June 24, 2011
LEWIS BRISBOIS BISGAARD & SMITH LLP
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By:
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/s/ Jeffrey S. Ranen
Jeffrey S. Ranen
Nathalie Adourian
Attorneys for Defendant GIUMARRA
VINEYARDS CORPORATION
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LEWI
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BRISBOI
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BISGAAR
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4823-6232-4745.1
2
STIPULATION AND ORDER TO EXTEND DEADLINES
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION
1 DATED: June 24, 2011
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3
By:
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/s/ Connie K. Liem
Connie K. Liem
Attorneys for Plaintiff U.S. Equal Employment
Opportunity Commission
6 DATED: June 24, 2011
CALIFORNIA RURAL LEGAL ASSISTANCE, INC.
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8
By:
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/s/ Megan Beaman
Megan Beaman
Attorney for Plaintiff-Intervenors Maribel Ochoa,
Delfina Ochoa, Jose Ochoa
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DATED: June 24, 2011
MARCOS CAMACHO, A LAW CORP.
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By:
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/s/ Mario Martinez
Mario Martinez
Attorney for Plaintiff-Intervenor Guadalupe
Martinez
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ORDER
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The Court has reviewed this stipulation and for good cause shown, grants the Stipulated
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19 Order.
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21
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23 IT IS SO ORDERED.
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Dated:
June 27, 2011
/s/ Oliver W. Wanger
UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:
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LEWI
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BRISBOI
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BISGAAR
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4823-6232-4745.1
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STIPULATION AND ORDER TO EXTEND DEADLINES
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