Opinion
Case No.: 1:11-CV-01549 LJO BAM
01-09-2013
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, v. ALIA CORPORATION d/b/a MCDONALDS, AND DOES 1-10, INCLUSIVE, Defendants
Anna Y. Park, SBN 164242 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Rumduol Vuong, SBN 264392 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Attorneys for Plaintiff U.S. EEOC
Anna Y. Park, SBN 164242
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
Rumduol Vuong, SBN 264392
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
Attorneys for Plaintiff U.S. EEOC
STIPULATION TO EXTEND
DISCOVERY DEADLINES
Plaintiff United States Equal Employment Opportunity Commission ("EEOC" or "Plaintiff") and Defendant Alia Corporation d/b/a McDonalds ("Defendant"), through their respective counsel of record, hereby stipulate pursuant to Rules 16 and 26 of the Federal Rules of Civil Procedure as follows:
1. Good Cause to Extend Discovery Deadlines
All parties and counsel for all parties have engaged in good faith efforts to further discovery in this case, including exchanging initial disclosures, engaging in written discovery and the taking of several depositions. However, there have been reasonable delays in providing responses to written requests and the scheduling of witnesses deposition. Counsel for both parties have worked cooperatively in providing extensions to deadlines for the purpose of adequately addressing the nature and scope of written discovery and to secure witness testimony.
Moreover, the parties are currently engaged in settlement discussions and will need additional time for discovery should these settlement discussions prove unsuccessful.
2. Stipulation to Extend Discovery Deadlines
The parties stipulate that the original Scheduling Conference Order (ECF No. 25) be amended to reflect the following new deadlines:
a. All non expert discovery shall be completed before March 8, 2013.
b. The parties are directed to disclose all expert witnesses, in writing, on or before March 29, 2013 and to disclose all supplemental experts on or before April 21, 2013.
IT IS SO STIPULATED.
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
By: ____________________
Rumie Vuong
Attorney for Plaintiff U.S. EEOC
BURNHAM BROWN
By: ____________________
Brendan Brownfield
Attorney for Defendant Alia Corporation
ORDER
Based on the Stipulation of the parties (Doc. 34), and for good cause shown, the Scheduling Conference Order (Doc. 25) shall be amended as follows:
The parties are ordered to complete all non expert discovery on or before March 8, 2013.
The parties are directed to disclose all expert witnesses, in writing, on or before March 29, 2013 and to disclose all supplemental experts on or before April 21, 2013. The written designation of retained and non retained experts shall be made pursuant to Rule 26(a)(2), (A) and (B) of the Federal Rules of Civil Procedure.
All other provisions of the Scheduling Conference Order shall otherwise remain in effect. IT IS SO ORDERED.
Barbara A. McAuliffe
UNITED STATES MAGISTRATE JUDGE