Munoz v. Home Depot USA, Inc.

1 GJALMYENSN M &. FHIANNLLEOYN, L, LJRP. , Bar No. 214096 BRANDON P. RAINEY, Bar No. 272341 One Walnut Creek Center 100 Pringle Avenue, Suite 500 Walnut Creek, CA 94596 Telephone: (925) 210-2800 Facsimile: (925) 945-1975 Attorneys for Defendants Haier US Appliance Solutions, Inc., d/b/a GE Appliances, and Home Depot USA, Inc. 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA ) Case No. 2:20-cv-00210-TLN-DB ROLANDO MUNOZ and JOANNA ) FRAIRE, ) STIPULATION AND ORDER 12 ) Plaintiffs, ) 13 ) vs. ) 14 ) HOME DEPOT USA, INC.; HAIER US ) APPLIANCE SOLUTIONS, INC. dba GE ) APPLIANCES, and DOES 1 to 50, ) inclusive, ) ) 17 Defendants. ) )

2 PLEASE TAKE NOTICE that, pursuant to Local Rule 143, Plaintiffs Rolando Munoz and Joanna Fraire and Defendants Haier US Appliance Solutions, Inc., d/b/a GE Appliances (“GEA”) and Home Depot USA, Inc. (“Home Depot”) have stipulated to continue the fact discovery, expert disclosure and rebuttal expert designation deadlines set in the Court’s initial pretrial scheduling order by three months (Dkt. 5). Good cause exists for the extension of those deadlines as a result of the coronavirus public health crisis, which has limited and will continue to limit the parties’ abilities to conduct discovery. See Fed. R. Civ. P. 16(b); Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992). Therefore, the parties respectfully request that the Court modify the deadlines in its initial pretrial scheduling order such that fact discovery will close on December 18, 2020, expert disclosures will be made by February 22, 2021, and rebuttal experts will be designated by March 30, 2021.

13 Dated: March 26, 2020 GLYNN & FINLEY, LLP JAMES M. HANLON, JR. BRANDON P. RAINEY One Walnut Creek Center Pringle Avenue, Suite 500 Walnut Creek, CA 94596

By /s/ Brandon P. Rainey Attorneys for Defendants Home Depot USA, Inc. and Haier US Appliance Solutions, Inc. dba GE Appliances

Dated: March 26, 2020 BOHM LAW GROUP, INC. LAWRENCE A. BOHM VICTORIA L. GUTIERREZ 4600 Northgate Boulevard, Suite 210 Sacramento, CA 95834

By /s/ Victoria L. Gutierrez Attorneys for Plaintiffs Joanna Fraire and Rolando Munoz

2 Good cause having been established to continue the discovery deadlines in the Court’s initial pretrial scheduling order (Dkt. 5), the Court hereby GRANTS the parties’ stipulation. Fact discovery will close on December 18, 2020, expert disclosures will be made by February 22, 2021, and rebuttal experts will be designated by March 30, 2021.

6 IT IS SO ORDERED.

7 DATED: March 26, 2020