Filed: Jul. 11, 2019
Latest Update: Jul. 11, 2019
Summary: STIPULATION TO CONTINUE DEADLINES TO COMPLETE FACT AND EXPERT DISCOVERY, AND TO HEAR DISPOSITIVE MOTIONS; ORDER (as modified) HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Luz Velarde ("Plaintiff") and Defendant Department of Motor Vehicles ("DMV" or "Defendant"), by and through their attorneys of record, jointly stipulate as follows: 1. WHEREAS, the Parties have continued to explore possible resolution of this action following the mediation with mediator Claudia Viera on May 28, 20
Summary: STIPULATION TO CONTINUE DEADLINES TO COMPLETE FACT AND EXPERT DISCOVERY, AND TO HEAR DISPOSITIVE MOTIONS; ORDER (as modified) HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Luz Velarde ("Plaintiff") and Defendant Department of Motor Vehicles ("DMV" or "Defendant"), by and through their attorneys of record, jointly stipulate as follows: 1. WHEREAS, the Parties have continued to explore possible resolution of this action following the mediation with mediator Claudia Viera on May 28, 201..
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STIPULATION TO CONTINUE DEADLINES TO COMPLETE FACT AND EXPERT DISCOVERY, AND TO HEAR DISPOSITIVE MOTIONS; ORDER (as modified)
HAYWOOD S. GILLIAM, JR., District Judge.
Plaintiff Luz Velarde ("Plaintiff") and Defendant Department of Motor Vehicles ("DMV" or "Defendant"), by and through their attorneys of record, jointly stipulate as follows:
1. WHEREAS, the Parties have continued to explore possible resolution of this action following the mediation with mediator Claudia Viera on May 28, 2019.
2. WHEREAS, a central issue in this matter is the amount of service credit Plaintiff has accumulated during her employment with DMV as it affects the type and amount of retirement benefits she is entitled to receive from the California Public Employees' Retirement System ("CalPERS") upon retirement.
3. WHEREAS, Plaintiff contends that DMV has improperly caused a decrease in the amount of service credit she has with the DMV, a claim which DMV denies.
4. WHEREAS, the Parties are working together to resolve a potential issue with Plaintiff's service credit with DMV and this is a critical issue that affects the course of this litigation and possible resolution.
5. WHEREAS, the Parties agree to extend the non-expert and expert discovery deadlines and the dispositive motion hearing deadline by 45 days to allow time for an orderly and efficient review, investigation, and potential resolution of the service credit issue, which may help resolve the case.
6. WHEREAS, pursuant to the Court's June 12, 2019 Revised Scheduling Order, the Court set the following deadlines:
Event Date
Close of Fact Discovery July 15, 2019
Exchange of Opening Expert Reports July 29, 2019
Exchange of Rebuttal Expert Reports August 12, 2019
Close of Expert Discovery August 26, 2019
Dispositive Motion Hearing Deadline October 3, 2019 at 2:00 p.m.
Pretrial Conference January 14, 2020 at 3:30 p.m.
7-Day Jury Trial February 3, 2020 at 8:30 a.m.
7. WHEREAS, in light of the above, the Parties have agreed to the following continued deadlines:
Event Date
Close of Fact Discovery August 29, 2019
Exchange of Opening Expert Reports September 12, 2019
Exchange of Rebuttal Expert Reports September 26, 2019
Close of Expert Discovery October 10, 2019
Dispositive Motion Hearing Deadline November 18, 2019 at 2:00 p.m. (or the
Court's next available date)
IT IS SO STIPULATED.
Respectfully Submitted,
Dated: July 9, 2019 XAVIER BECERRA
Attorney General of California
By: /s/ Jorge Aguilar II
JORGE AGUILAR II
Deputy Attorney General
Attorneys for Defendants Department of
Motor Vehicles; Carrie Stanton
Dated: July 9, 2019 ROGERS JOSEPH O'DONNELL
By: /s/Aaron M. Scolari
AARON P. SILBERMAN
AARON M. SCOLARI
Attorneys for Plaintiff
LUZ VELARDE
ORDER
Pursuant to the Stipulation of the Parties and for good cause shown, the Court SETS the following schedule:
Event Date
Close of Fact Discovery August 29, 2019
Exchange of Opening Expert Reports September 12, 2019
Exchange of Rebuttal Expert Reports September 26, 2019
Close of Expert Discovery October 10, 2019
Dispositive Motion Hearing Deadline November 21, 2019 at 2:00 p.m.
Pretrial Conference January 14, 2020 at 3:00 p.m.
7-Day Jury Trial February 3, 20120 at 8:30 a.m.
IT IS SO ORDERED.
