Filed: May 03, 2016
Latest Update: May 03, 2016
Summary: JOINT STIPULATION TO AMEND EXPERT DATES JON S. TIGAR , District Judge . The Parties through their respective attorneys of record respectfully request the Court extend the expert disclosure and report deadlines as set forth in Case Management Order ("CMO") No. 2. Since entry CMO No. 2, the Parties have conducted discovery of the Case Pool Selections, served written requests for the production of documents, and are collectively scheduling deposition dates. The Parties have conducted several
Summary: JOINT STIPULATION TO AMEND EXPERT DATES JON S. TIGAR , District Judge . The Parties through their respective attorneys of record respectfully request the Court extend the expert disclosure and report deadlines as set forth in Case Management Order ("CMO") No. 2. Since entry CMO No. 2, the Parties have conducted discovery of the Case Pool Selections, served written requests for the production of documents, and are collectively scheduling deposition dates. The Parties have conducted several m..
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JOINT STIPULATION TO AMEND EXPERT DATES
JON S. TIGAR, District Judge.
The Parties through their respective attorneys of record respectfully request the Court extend the expert disclosure and report deadlines as set forth in Case Management Order ("CMO") No. 2. Since entry CMO No. 2, the Parties have conducted discovery of the Case Pool Selections, served written requests for the production of documents, and are collectively scheduling deposition dates.
The Parties have conducted several meet-and-confers regarding expert disclosures and reports pursuant to CMO No. 2—which inadvertently contemplated expert disclosures and reports due prior to the close of discovery. Pursuant to CMO No. 1, discovery does not close until July 1, 2016. As such, the Parties agree that expert disclosures and reports be due after the close of discovery. No other dates will be affected by this change. Discovery will still close on July 1, 2016, and the dispositive motion deadlines and trial dates will be unaffected.
Proposed amendments to CMO No. 2:
Event Deadline New Deadline
Expert disclosures and reports May 2, 2016 July 15, 2016
Expert rebuttal reports May 27, 2016 August 9, 2016
Expert deposition period begins June 20, 2016 August 22, 2016
Expert deposition period ends July 22, 2016 September 2, 2016
SO STIPULATED.
ATTESTATION FOR COMPLIANCE WITH CIVIL L.R. 5-1(i)(3)
I, Jacob Rusch, declare under penalty of perjury and pursuant to the laws of California and the United States that I have in my possession e-mail correspondence from Aurelio J. Perez that the content of this Joint Stipulation is acceptable to all persons required to sign it. I declare that this Stipulation was signed in Minneapolis, Minnesota, on May 3, 2016.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
