Lema v. Modesto Hospitality, LLC

Full title: GENEVA LEMA, Plaintiff, v. MODESTO HOSPITALITY, LLC, DOES 1 through 50…

Court: UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

Date published: Jul 10, 2012

Case No. 1:10-cv-02018-AWI-GSA (E.D. Cal. Jul. 10, 2012)

Opinion

Case No. 1:10-cv-02018-AWI-GSA

07-10-2012

GENEVA LEMA, Plaintiff, v. MODESTO HOSPITALITY, LLC, DOES 1 through 50 Defendants.

TIMOTHY S. THIMESCH, ESQ. THIMESCH LAW OFFICES Attorneys for Plaintiff GENEVA LEMA BASHAM LAW GROUP GARY R. BASHAM AARON R. JACKSON Attorneys for Defendant MODESTO HOSPITALITY, LLC

Gary S. Austin

Thimesch Law Offices

TIMOTHY S. THIMESCH, ESQ., No. 148213

Attorneys for Plaintiff GENEVA LEMA

GARY R. BASHAM (Bar No. 130119)

AARON R. JACKSON (Bar No. 233816)

BASHAM LAW GROUP

Attorneys for Defendant

MODESTO HOSPITALITY

STIPULATION AND ORDER

REGARDING DISCOVERY

DEADLINES

TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS:

The Parties have made significant progress in their settlement discussions, and they are in the process of negotiating a Consent Decree and (Proposed) Order. Due to the size of the property and the scope of issues, the negotiations regarding the terms of the Consent Decree could take several weeks.

In an effort to avoid incurring unnecessary discovery costs while these negotiations proceed, the Parties request that the following deadlines be modified.

• The Parties request that the discovery deadlines be moved to the following dates: (1) Non-Expert Discovery, September 28, 2012; (2) Expert Disclosure, September 24, 2012; (3) Supplemental Expert Disclosure, October 5, 2012; and (4) Expert Discovery, November 5, 2012;
• The Parties request that the motion filing deadlines be moved to the following dates: Non-dispositive motions, November 12, 2012; and Dispositive Motions, January 11, 2013;
• The Parties request that the Pre-Trial Conference be moved to Thursday, March 14, 2013 at 8:30 a.m., or the next nearest date that the Court is available;
• The Parties additionally request that the Trial Date be moved to May 14, 2013 at 8:30 a.m., or the next nearest date that the Court is available.

IT IS SO STIPULATED:

TIMOTHY S. THIMESCH, ESQ.

THIMESCH LAW OFFICES

By: _____________

Attorneys for Plaintiff

GENEVA LEMA

BASHAM LAW GROUP

By: _____________

GARY R. BASHAM

AARON R. JACKSON

Attorneys for Defendant

MODESTO HOSPITALITY, LLC

ORDER

The Court hereby ADOPTS the parties' Stipulation as outlined above. IT IS SO ORDERED.

Gary S. Austin

UNITED STATES MAGISTRATE JUDGE