SECOND 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.
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). Prior to the March 13, 2012 discovery deadline the parties had exchanged written discovery, and attempted to schedule all depositions, however found this extremely difficult, despite working diligently to coordinate the calendars of the witnesses and counsel for the three parties. As a result, on February 14, 2013 the parties submitted a stipulated request to extend the discovery cutoff to April 30, 2013. On March 7, 2013, the Court granted that requested extension.
Subsequent to the stipulated request for an extension, Defendant cancelled depositions that the EEOC and Intervenor had noticed for February 21, 2013 due to childcare issues, and depositions the EEOC and Intervenor had scheduled for February 26, March 1, and March 4, 2013 due to Defendant counsel's illness. Despite the counsels' efforts, the parties have been unable to reschedule the cancelled depositions, as well as depositions subsequently noticed, prior to the April 30, 2013 discovery cutoff.
The parties therefore, through this stipulation and request, hereby request an additional extension of the discovery cutoff to June 7, 2013. To avert the scheduling difficulties previously experienced, the parties incorporate into their stipulation the following deposition discovery schedule:
May 9, 2013: George Perez
May 10, 2013: Anthony Okon
May 16, 2013: Pastor Hightower, Loreto Okon
May 17, 2013: Eric Brown, Eric Wilson
May 29, 2013: FRCP 30(b)(6) deposition of Maita Chevrolet Geo, William Belliguerie
May 30, 2013: Kevin Seppinni, Mark Knowles
May 31, 2013: Stephen Christianson, Peter Allen
The final day for non-expert discovery will be extended to June 7, 2013.
E-filing certification: I, Cindy O'Hara, as counsel for Plaintiff EEOC, certify that I have obtained the concurrence of Isela Perez as counsel for Defendant, and Alan Reinach as counsel for ...