Filed: Jul. 29, 2016
Latest Update: Jul. 29, 2016
Summary: STIPULATION AND ORDER TO MODIFY CASE MANAGEMENT SCHEDULE CONSOLIDATED CLASS ACTION CHARLES R. BREYER , District Judge . Lead Plaintiff Vinod Patel ("Lead Plaintiff") and Defendants Geron Corporation, John A. Scarlett, Olivia K. Bloom, and Stephen M. Kelsey (collectively "Defendants" and together with Lead Plaintiff, the "Parties"), by and through their undersigned counsel, hereby stipulate as follows: WHEREAS, on November 6, 2015, the Parties filed their Joint Case Management Statement an
Summary: STIPULATION AND ORDER TO MODIFY CASE MANAGEMENT SCHEDULE CONSOLIDATED CLASS ACTION CHARLES R. BREYER , District Judge . Lead Plaintiff Vinod Patel ("Lead Plaintiff") and Defendants Geron Corporation, John A. Scarlett, Olivia K. Bloom, and Stephen M. Kelsey (collectively "Defendants" and together with Lead Plaintiff, the "Parties"), by and through their undersigned counsel, hereby stipulate as follows: WHEREAS, on November 6, 2015, the Parties filed their Joint Case Management Statement and..
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STIPULATION AND ORDER TO MODIFY CASE MANAGEMENT SCHEDULE
CONSOLIDATED CLASS ACTION
CHARLES R. BREYER, District Judge.
Lead Plaintiff Vinod Patel ("Lead Plaintiff") and Defendants Geron Corporation, John A. Scarlett, Olivia K. Bloom, and Stephen M. Kelsey (collectively "Defendants" and together with Lead Plaintiff, the "Parties"), by and through their undersigned counsel, hereby stipulate as follows:
WHEREAS, on November 6, 2015, the Parties filed their Joint Case Management Statement and Order (the "Initial CMS") (ECF No. 94) proposing a litigation schedule and discovery plan for this action;
WHEREAS, on November 13, 2015, the Court expressly adopted certain dates set forth in the Initial CMS, and, although not reflected in the Minute Entry (ECF No. 95), presumably approved the remaining dates set forth in the Initial CMS;
WHEREAS, on June 9, 2016, the Court entered an order modifying certain dates set forth in the Initial CMS (ECF No. 101) (the "Modified Scheduling Order");
WHEREAS, the Parties engaged in informal, targeted discovery and attempted to resolve the dispute amicably, but have been unable to do so to date;
WHEREAS, on July 8, 2016, Lead Plaintiff served discovery on Defendants, including requests for the production of documents;
WHEREAS, Defendants intend to serve discovery on Lead Plaintiff, including requests for the production of documents;
WHEREAS, the Parties have met and conferred and agreed to a new case management schedule that would extend the time for the Parties to substantially complete their respective document productions by approximately one month; and
WHEREAS, this one month extension for the Parties to substantially complete their respective document productions would not alter any other dates set forth in the Modified Scheduling Order;
WHEREFORE, IT IS HEREBY STIPULATED AND AGREED that,
1. The following amended case management schedule should be adopted and the dates highlighted in the chart below should replace the dates set forth in the Modified Scheduling Order:
EVENT DATE
Exchange of initial disclosures December 11, 2015
Plaintiff to file class certification motion August 12, 2016
Deadline for substantial completion of document October 31, 2016
productions
Defendants to respond to Plaintiff's class September 26, 2016
certification motion
Plaintiff's reply in support of class certification November 7, 2016
motion
Hearing on Plaintiff's class certification motion December 2, 2016, or on a date set by
the Court
Fact discovery cut-off February 24, 2017
Last day to amend pleadings or add parties March 10, 2017
Deadline for Plaintiff to submit expert reports April 7, 2017
Deadline for Defendants to submit expert reports May 8, 2017
Deadline for Plaintiff to submit rebuttal expert June 7, 2017
reports, if any
Expert discovery cut-off June 23, 2017
Defendants to file motion for summary judgment July 14, 2017
and/or summary adjudication
Plaintiff's to respond to Defendants' motion for August 28, 2017
summary judgment and/or summary adjudication
Defendants reply in support of Defendants' motion October 12, 2017
for summary judgment and/or summary adjudication
Last day to conduct settlement conference No later than 25 days after Court's
ruling on all dispositive motions
Deadline to serve and file Rule 26(a)(3) disclosures No later than 30 days after Court's
ruling on all dispositive motions
Deadline to serve motions in limine No later than 30 days after Court's
ruling on all dispositive motions
Deadline to serve oppositions to motions in limine No later than 60 days after Court's
ruling on all dispositive motions
Deadline for the Parties to exchange copies of all No later than 60 days after Court's
exhibits, summaries, charts, and diagrams to be used ruling on all dispositive motions
at trial other than solely for impeachment
Deadline to file joint proposed final pretrial order No later than 73 days after Court's
and other materials as set forth in the Court's ruling on all dispositive motions
"Guidelines for Trial and Final Pretrial Conference
in Civil Jury Cases"
Pre-trial conference No later than 80 days after Court's
ruling on all dispositive motions
Trial to commence No later than 90 days after Court's
ruling on all dispositive motions
ORDER
Pursuant to the foregoing stipulation, and good cause appearing, IT IS SO ORDERED.
