Opinion
Case No. 2:11-CV-03133-MCE-KJN
03-06-2013
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, ANTHONY OKON, Plaintiff/Intervenor v. MAITA CHEVROLET GEO, Defendant.
ERIC C. BELLAFRONTO LITTLER MENDELSON, P.C. Attorneys for Defendant MAITA CHEVROLET GEO U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Attorneys for Plaintiff U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION ALAN J. REINACH CHURCH STATE COUNCIL Attorneys for Intervenor Anthony Okon
ERIC C. BELLAFRONTO, SBN 162102
BRIAN T. McMILLAN, SBN 111890
ISELA PÉREZ, Bar No. 267859
LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, California 95113.2303
Telephone: 408.998.4150
Facsimile: 408.288.5686
Attorneys for Defendant
WILLIAM R. TAMAYO, SBN 084965
JONATHAN PECK, VA SBN 12303
CINDY O'HARA, SBN 114555
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
San Francisco District Office
350 The Embarcadero, Suite 500
San Francisco, CA 94105-1260
Telephone: 415. 625.5653
Facsimile: 415.625.5657
Attorneys for Plaintiff
ALAN J. REINACH, SBN 196899
CHURCH STATE COUNCIL
2686 Townsgate Road
Westlake Village, CA 91361
Telephone: 805.413.7398
Facsimile: 805.497.7099
Attorneys for Plaintiff/Intervenor
STIPULATION AND ORDER TO EXTEND
DISCOVERY CUT-OFF
[Local Rule 143]
Trial Date: January 13, 2014
This Stipulation is entered into by and among Plaintiff Equal Employment Opportunity Commission ("EEOC"), Intervenor Anthony Okon ("Intervenor"), and Defendant Maita Chevrolet Geo ("Defendant"), by and through their attorneys of record.
WHEREAS, on May 21, 2012, the Court issued a Pretrial Scheduling Order establishing the deadline for non-expert discovery as March 13, 2013 ,and a trial date of January 13, 2014 (Dkt. No. 21);
WHEREAS, the parties have diligently pursued, but have not yet completed, the exchange of written discovery and the taking of depositions of key witnesses for Plaintiff, Intervenor and Defendant;
WHEREAS, Defendant conducted the first day of Intervenor's deposition;
WHEREAS, the parties have scheduled or are in the processing of scheduling at least ten additional depositions and the parties are working cooperatively and diligently to accommodate the calendars of not only the witnesses but of the three counsel as well, which has been difficult;
WHEREAS, there have been no previous modifications to the dates set by the Court's Pretrial Scheduling Order;
WHEREAS, the parties in good faith believe that additional time is necessary in order to complete the depositions of key witnesses, respond to written discovery, and fully explore the possibility of settlement;
WHEREAS, the parties agree that extending the deadline for discovery would serve the interests of judicial economy and not cause any prejudice;
THEREFORE, IT IS HEREBY STIPULATED by and among the parties, through their respective counsel, that the Court modify the deadline set forth in the Pretrial Scheduling Order by approximately thirty (30) days to extend the cut -off for non-expert discovery until April 30, 2013.
We hereby attest that we have on file all holographic signatures corresponding to any signatures indicated by a conformed signature (/s/) within this e-filed document.
By: ____________________
ERIC C. BELLAFRONTO
LITTLER MENDELSON, P.C.
Attorneys for Defendant
MAITA CHEVROLET GEO
By: ____________________
CINDY O'HARA
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
Attorneys for Plaintiff
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
By: ___________________
ALAN J. REINACH
CHURCH STATE COUNCIL
Attorneys for Intervenor
Anthony Okon
ORDER
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the parties' stipulation, above, is approved and adopted as the Order of this Court, as follows: The cut-off for non-expert discovery in the above-captioned matter shall be extended from March 13, 2013 to April 30, 2013.
IT IS SO ORDERED
________________________________________
MORRISON C. ENGLAND, JR., CHIEF JUDGE
UNITED STATES DISTRICT JUDGE