United States Equal Employment Opportunity Commission v. Giumarra Vineyards Corporation
Filing
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STIPULATION and ORDER to EXTEND DEADLINES: Discovery Deadline: 12/30/2011., Expert Discover Deadline: 3/30/2012., Dispositive Motions shall be filed by 10/30/2012, Settlement Conference is set for 1/30/2012 at 01:30 AM in Courtroom 6 (MJS) before Mag istrate Judge Michael J. Seng., Trial Confirmation Hearing is set for 4/13/2012 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii. Court Trial is set for 1/12/2012 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii signed by Magistrate Judge Michael J. Seng on 11/16/2011. (Yu, L)
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MEGAN BEAMAN (SBN 261539)
California Rural Legal Assistance, Inc.
1460 6th Street
Coachella, CA 92236
Telephone: (760) 398-7261
Facsimile: (760) 398-1050
Attorneys for Plaintiffs/Intervenors
DELFINA OCHOA, MARIBEL OCHOA, and JOSÉ OCHOA
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MARIO MARTINEZ (SBN 200721)
Marcos Camacho, A Law Corporation
1227 California Avenue
Bakersfield, CA 93304
Telephone: (661) 324-8100
Facsimile: (661) 324-8103
Attorneys for Plaintiffs/Intervenors
DELFINA OCHOA, MARIBEL OCHOA, JOSÉ OCHOA, and GUADALUPE MARTINEZ
Additional Counsel listed on Page Two
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,
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Plaintiff,
Case No.: 1:09−CV−02255−AWI-MJS
AMENDED STIPULATION AND ORDER
TO EXTEND DEADLINES
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DELFINA OCHOA, MARIBEL OCHOA,
JOSÉ OCHOA, and GUADALUPE
MARTINEZ
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The Honorable Michael J. Seng
U.S. Magistrate Judge
Action filed: December 29, 2009
Plaintiffs/Intervenors
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vs.
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GIUMARRA VINEYARDS CORPORATION
and DOES 1-10,
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Defendants.
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EEOC v. Giumarra Vineyards Corp.
Stipulation to Extend Deadlines
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MICHAEL MEUTER (SBN 161554)
California Rural Legal Assistance, Inc.
3 Williams Road
Salinas CA 93905
Telephone: (831) 757-5221
Facsimile: (831) 757-6212
Attorneys for Plaintiffs/Intervenors
DELFINA OCHOA, MARIBEL OCHOA, and JOSÉ OCHOA
TO THE HONORABLE COURT AND TO ALL PARTIES OF AND COUNSEL
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OF RECORD:
The parties stipulate that the current deadlines be extended for good cause, namely the
need for more time to: (1) complete outstanding discovery which has resulted from conflicts in
counsel schedules; (2) resolve outstanding discovery disputes; and (3) allow for expert
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witnesses’ thorough and complete preparation for this matter. The parties have engaged in
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mediation in this matter and are continuing related discussions.
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In good faith and by agreement of the parties, through counsel undersigned, and pursuant
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to the Court’s Minute Order of October 17, 2011, it is respectfully requested that a revised
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scheduling order be entered to reflect the following stipulated deadlines:
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The deadline for completing discovery shall be December 30, 2011;
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2.
The deadline for filing dispositive motions shall be January 30, 2012;
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3.
The settlement conference shall take place on January 30, 2012; [By order of the
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Court, the settlement conference shall begin at 1:30 p.m. in courtroom 6.]
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The expert disclosure deadline shall be February 28, 2012;
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5.
The expert discovery deadline shall be March 30, 2012;
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6.
The pretrial conference shall take place on or after April 13, 2012;
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7.
The trial date shall be continued to June 11, 2012, or on a subsequent date
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convenient to the Court. [By order of the Court, the trial will begin June 12, 2012 at 8:30
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a.m. in Courtroom 2.]
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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
EEOC v. Giumarra Vineyards Corp.
Stipulation to Extend Deadlines
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purpose of delay.
This Stipulation may be signed in counter-parts, each counter-part having the same force
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and effect as originals, and facsimile signatures shall be deemed to have the same force as
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originals.
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IT IS SO STIPULATED.
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DATED: November 16, 2011
LEWIS BRISBOIS BISGAARD & SMITH LLP
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By:
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/s/ Jeffrey S. Ranen
Jeffrey S. Ranen
Alexander J. Harwin
Attorneys for Defendant GIUMARRA
VINEYARDS CORPORATION
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DATED: November 1, 2011
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U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION
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By:
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DATED: November 1, 2011
/s/ Rumduol Vuong
Rumduol Vuong
Attorneys for Plaintiff U.S. Equal Employment
Opportunity Commission
CALIFORNIA RURAL LEGAL ASSISTANCE, INC.
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By:
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/s/ Megan Beaman
Megan Beaman
Attorney for Plaintiff-Intervenors Maribel Ochoa,
Delfina Ochoa, Jose Ochoa
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EEOC v. Giumarra Vineyards Corp.
Stipulation to Extend Deadlines
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DATED: November 1, 2011
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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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Order but moves the trial date to June 12, 2012 and sets the January 30, 2012, settlement
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conference to begin at 1:30 p.m.
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IT IS SO ORDERED.
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November 16, 2011
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/S/ Michael J. Seng
United States Magistrate Judge
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EEOC v. Giumarra Vineyards Corp.
Stipulation to Extend Deadlines
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