Opinion
1:22-cv-07341-JGK
09-21-2022
JESSICA MASON, Plaintiff, v. THEMARYSUE, LLC, a Delaware limited liability corporation, GAMURS, INC, a Delaware business corporation, TRINET HR III, INC., a California business corporation, ANDREW EISBROUCH, individually, DAN VAN WINKLE, individually, and KAILA HALE-STERN, individually, Defendants.
Scott Obome, Anthony Copple, JACKSON LEWIS P.C. Attorneys for Defendants THEMARYSUE, LLC, Gamurs, Inc., Andrew Eisbrouch, Dan Van Winkle and Kaila Hale-Stern
Scott Obome, Anthony Copple, JACKSON LEWIS P.C. Attorneys for Defendants THEMARYSUE, LLC, Gamurs, Inc., Andrew Eisbrouch, Dan Van Winkle and Kaila Hale-Stern
JOINT STATUS REPORT
Plamtrfr Jessica Mason ("Plaintiff) and Defendants TheMarySue, LLC ("TMS") Gamurs, Inc. ("Gamurs"), Andrew Eisbrouch, Dan Van Winkle, and Kaila Hale-Stern ("TMS Defendants"), by and through their undersigned counsel, respectfully submit the following Rule 26(f) Report and Joint Proposed Case Schedule.
1. Proposed Case Schedule and Deadlines:
The Parties jointly propose the following case schedule and deadlines:
Event
Current
Proposed Date
Fact discovery to be completed
9/23/2022
10/31/2022
File all pleadings pursuant to Fed.R.Civ.P. 7(a) and 15
9/23/0022
10/31/2022
Join all claims remedies and parties pursuant to Fed.R.Civ.P. 18 and 19
9/23/2022
10/31/2022
Pretrial and discovery motions due
9/23/2022
10/31/2022
Dispositive motions due
9/23/2022
12/01/2022
Joint ADR report due
10/23/2022
10/23/2022
Expert Discovery
9/23/2022
10/31/2022
Pretrial Order due
N/A
N/A
2. Other Items:
a. Alternative Dispute Resolution: The parties have not held settlement discussions, but discussed participating in alternative dispute resolution. Plaintiff believes ADR will assist in the resolution of this case. Defendants are not interested in settlement or ADR and are intent on fully defending themselves in this matter.
b. Consent to a Magistrate: The parties have discussed consenting to a magistrate. Plaintiff has shared her position with Defendants regarding consent to a Magistrate Judge. Defendants do not yet have a position with respect to a Magistrate Judge.
c. E-Discovery: The parties have discussed electronic discovery,