Filed: Mar. 21, 2017
Latest Update: Mar. 21, 2017
Summary: STIPULATION TO EXTEND DISCOVERY AND RELATED DEADLINES JOHN A. MENDEZ , District Judge . Plaintiffs Bruce Kaufman, Chris Gonzalez, Kathryn Van Kopp, Keith Welday, Tom Bauser, Mark Jaeger, Paul Neumann, Linda Willis, Akindale Carter, Bernadette Carter, Mike Campbell, Bart Hillard, Joshua Roach, Gary Williams, Robert Hollandsworth, Louis Serpa, Agnes Marcallino, Bryce Williams, Ramon Hurtado, Elaheh Salehi, Shannon Betts, Lisa Ladner, and Caren Winegarner ("Plaintiffs") and defendant Rite Aid
Summary: STIPULATION TO EXTEND DISCOVERY AND RELATED DEADLINES JOHN A. MENDEZ , District Judge . Plaintiffs Bruce Kaufman, Chris Gonzalez, Kathryn Van Kopp, Keith Welday, Tom Bauser, Mark Jaeger, Paul Neumann, Linda Willis, Akindale Carter, Bernadette Carter, Mike Campbell, Bart Hillard, Joshua Roach, Gary Williams, Robert Hollandsworth, Louis Serpa, Agnes Marcallino, Bryce Williams, Ramon Hurtado, Elaheh Salehi, Shannon Betts, Lisa Ladner, and Caren Winegarner ("Plaintiffs") and defendant Rite Aid C..
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STIPULATION TO EXTEND DISCOVERY AND RELATED DEADLINES
JOHN A. MENDEZ, District Judge.
Plaintiffs Bruce Kaufman, Chris Gonzalez, Kathryn Van Kopp, Keith Welday, Tom Bauser, Mark Jaeger, Paul Neumann, Linda Willis, Akindale Carter, Bernadette Carter, Mike Campbell, Bart Hillard, Joshua Roach, Gary Williams, Robert Hollandsworth, Louis Serpa, Agnes Marcallino, Bryce Williams, Ramon Hurtado, Elaheh Salehi, Shannon Betts, Lisa Ladner, and Caren Winegarner ("Plaintiffs") and defendant Rite Aid Corporation ("Rite Aid"), acting through their respective counsel of record, hereby stipulate, and respectfully request, that the Court grant a three-month extension of discovery and all related deadlines for all related cases that do not currently have a trial date.
In support of their request, the parties stipulate as follows:
1. On June 9, 2016, this Court entered a scheduling order (ECF 46). The scheduling order set April 28, 2017, for the close of discovery for all related cases, and October 23, 2017, as the trial date for Bruce Kaufman v. Rite Aid Corp., No. 2:14-CV-01961 JAM-EFB; Chris Gonzalez v. Rite Aid Corp., No. 2:14-CV-01963 JAM-EFB; and Kathryn Van Kopp v. Rite Aid Corp., No. 2:14-CV-01965 JAM-EFB. June 9, 2016 Order, at 5, 8. No other trial dates have been set.
2. The parties do not seek a discovery extension for Kaufman, Gonzalez or Van Kopp (i.e., the cases in which a trial date has been set).
3. The parties and their undersigned counsel currently have a trial scheduled in the Central District of California in another Rite Aid Store Manager case on May 16, 2017.
4. The parties have diligently pursued discovery in these matters, have taken numerous depositions, have served and responded to written discovery, and have produced thousands of documents.
5. No previous discovery extensions have been sought or granted in these related matters. This stipulation will not delay trial because the parties do not seek to extend discovery in any case with a trial date.
6. In order to complete the many depositions needed in these related cases, and to accommodate the schedules of parties and their counsel, the parties therefore agree and respectfully request that the Court extend the discovery completion deadline, and all related deadlines, in the following 14 actions not yet scheduled for trial:
• Keith Welday v. Rite Aid Corp., No. 2:13-CV-02439 JAM-EFB;
• Tom Bauser v. Rite Aid Corp., No. 2:14-CV-01946 JAM-EFB;
• Mark Jaeger v. Rite Aid Corp., No. 2:14-CV-01960 JAM-EFB;
• Paul Neumann v. Rite Aid Corp., No. 2:15-CV-00623 JAM-EFB;
• James Kilgore et al. v. Rite Aid Corp., No. 2:15-CV-02150 JAM-EFB;
• Mike Campbell v. Rite Aid Corp., No. 2:15-CV-02396 JAM-EFB;
• Bart Hillard et al. v. Rite Aid Corp., No. 1:15-CV-01748 JAM-EFB;
• Robert Hollandsworth v. Aid Corp., No. 2:15-CV-02597 JAM-EFB;
• Destrea Bell et al. v. Rite Aid Corp., No. 1:15-CV-01872 JAM-EFB;
• Bryce Williams v. Rite Aid Corp., No. 1:15-CV-01874 JAM-EFB;
• Ramon Hurtado v. Rite Aid Corp., No. 2:15-CV-02594 JAM-EFB;
• Elaheh Salehi et al. v. Rite Aid Corp., No. 2:16-CV-00174 JAM-EFB;
• Lisa Ladner v. Rite Aid Corp., No. 2:16-CV-00211 JAM-EFB; and
• Caren Winegarner v. Rite Aid Corp., No. 2:16-CV-01028 JAM-EFB.
7. The parties respectfully request that the Court extend the deadlines in the cases listed above in paragraph 6, as follows:
• Close of discovery extended from April 28, 2017, to July 28, 2017;
• Dispositive motion deadline extended from July 11, 2017, to October 10, 2017; and
• Dispositive motion hearing date extended from August 8, 2017, to November 7, 2017 at 1:30 p.m.
This stipulation is filed by Justin M. Scott. All other signatories listed, and on whose behalf the filing is submitted, concur in the filing's content and have authorized this filing.
ORDER GRANTING STIPULATION TO EXTEND DISCOVERY AND RELATED DEADLINES
On the stipulation of the parties, and good cause appearing therefor,
IT IS ORDERED that the deadlines in the following cases are extended as follows: (1) the close of discovery is extended from April 28, 2017, to July 28, 2017; (2) the dispositive motion deadline is extended from July 11, 2017, to October 10, 2017; and (3) the dispositive motion hearing date is continued from August 8, 2017, to November 7, 2017 at 1:30 p.m.
This order applies only to the following related cases:
• Keith Welday v. Rite Aid Corp., No. 2:13-CV-02439 JAM-EFB;
• Tom Bauser v. Rite Aid Corp., No. 2:14-CV-01946 JAM-EFB;
• Mark Jaeger v. Rite Aid Corp., No. 2:14-CV-01960 JAM-EFB;
• Paul Neumann v. Rite Aid Corp., No. 2:15-CV-00623 JAM-EFB;
• James Kilgore et al. v. Rite Aid Corp., No. 2:15-CV-02150 JAM-EFB;
• Mike Campbell v. Rite Aid Corp., No. 2:15-CV-02396 JAM-EFB;
• Bart Hillard et al. v. Rite Aid Corp., No. 1:15-CV-01748 JAM-EFB;
• Robert Hollandsworth v. Aid Corp., No. 2:15-CV-02597 JAM-EFB;
• Destrea Bell et al. v. Rite Aid Corp., No. 1:15-CV-01872 JAM-EFB;
• Bryce Williams v. Rite Aid Corp., No. 1:15-CV-01874 JAM-EFB;
• Ramon Hurtado v. Rite Aid Corp., No. 2:15-CV-02594 JAM-EFB;
• Elaheh Salehi et al. v. Rite Aid Corp., No. 2:16-CV-00174 JAM-EFB;
• Aaron Guzman et al. v. Rite Aid Corp., No. 2:16-CV-00211 JAM-EFB; and
• Caren Winegarner v. Rite Aid Corp., No. 2:16-CV-01028 JAM-EFB.
