Opinion
2:18-cv-00214-TLN-AC
07-21-2021
ROMEO & JULIETTE, INC., a California Corporation, Plaintiff, v. KEN WU, an individual, Defendant. KEN WU, an individual, Cross-Complainant, v. ROMEO & JULIETTE, INC., a California Corporation, and DOES 1-25, inclusive, Cross-Defendants.
OGNIAN A. GAVRILOV, ESQ. (258583) GREGORY P. O'DEA, ESQ. (110966) GAVRILOV & BROOKS, Attorney for Plaintiff and Cross-Defendant ROMEO & JULIETTE, INC.
OGNIAN A. GAVRILOV, ESQ. (258583) GREGORY P. O'DEA, ESQ. (110966) GAVRILOV & BROOKS, Attorney for Plaintiff and Cross-Defendant ROMEO & JULIETTE, INC.
JOINT STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER TO CONTINUE ALL DATES DUE TO CORONAVIRUS
Troy L Nunley, United States District Judge
TO THE COURT:
Plaintiff/Cross-Defendant ROMEO & JULIETTE, INC. (“plaintiff”) and Defendant/Cross-Complainant KEN WU (“defendant”) hereby submit this Stipulation and [Proposed] Order to the Court for approval.
WHEREAS, the deadline to complete non-expert discovery is August 9, 2021;
WHEREAS, the designation of expert witnesses in this matter is presently set for September 9, 2021, with any supplemental designation due 20 days later;
WHEREAS, the deadline to file dispositive motions is January 7, 2022;
WHEREAS, the parties deferred multiple depositions due to the pandemic and the public health emergency in effect in the State of California and the County of Sacramento which required people to avoid congregating and to avoid non-essential travel and business;
WHEREAS, conditions of the pandemic have significantly improved over the past month and the State of California and the County of Sacramento have revised the public health orders to permit the resumption of most activities;
WHEREAS. the parties seek to now complete multiple depositions and the depositions are in the process of being set by the parties;
WHEREAS, no trial date has yet been set in this matter;
WHEREAS, the parties have met and conferred and hereby stipulate and agree that a continuance of all dates for 90 days will allow time for the parties to take and complete the multiple depositions that had been deferred due to the pandemic conditions;
WHEREFORE, the parties hereby stipulate, and respectfully ask the Court to modify the Scheduling Order by continuing all dates, including the expert and non-expert discovery cut offs, the filing deadline for dispositive motions, by 90 days, and without prejudice to requesting an additional extension of these dates should the public health emergency so require. The parties will file a Joint Notice of Trial Readiness not later than 30 days after receiving the Court's ruling(s) on the last filed dispositive motion. If the parties do not intend to file dispositive motions, the parties will file a Joint Notice of Trial Readiness not later than 120 days after the close of discovery and the notice shall include statements of intent to forego the filing of dispositive motions. After review of the parties'
Joint Notice of Trial Readiness, the Court will issue an order that sets forth dates for a Final Pretrial Conference and Trial.
IT IS SO STIPULATED.
ORDER
Pursuant to the stipulation of the parties, all the deadlines previously set by the Court in this case, including the non-expert and expert discovery cut off, expert disclosures and deadline for filing dispositive motions, are hereby extended by 180 days. The parties will file a Joint Notice of Trial Readiness not later than 30 days after receiving the Court's ruling(s) on the last filed dispositive motion. If the parties do not intend to file dispositive motions, the parties will file a Joint Notice of Trial Readiness not later than 120 days after the close of discovery and the notice shall include statements of intent to forego the filing of dispositive motions. After review of the parties' Joint Notice of Trial Readiness, the Court will issue an order that sets forth dates for a Final Pretrial Conference and Trial.
IT IS SO ORDERED.