Filed: Jan. 13, 2015
Latest Update: Jan. 13, 2015
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND DISCOVERY DATES EDWARD M. CHEN, District Judge. JOINT STIPULATION 1. Pursuant to Local Rule 6-2, Plaintiff Paul A. Redd, Jr. and Defendant Michael D. Daley, by and through their respective counsel of record, hereby jointly stipulate and respectfully request the Court enter an order as follows: 2. The October 20, 2014, Case Management and Pretrial Order for Jury Trial set the pre-trial conference date on May 12, 2015, and tri
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND DISCOVERY DATES EDWARD M. CHEN, District Judge. JOINT STIPULATION 1. Pursuant to Local Rule 6-2, Plaintiff Paul A. Redd, Jr. and Defendant Michael D. Daley, by and through their respective counsel of record, hereby jointly stipulate and respectfully request the Court enter an order as follows: 2. The October 20, 2014, Case Management and Pretrial Order for Jury Trial set the pre-trial conference date on May 12, 2015, and tria..
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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND DISCOVERY DATES
EDWARD M. CHEN, District Judge.
JOINT STIPULATION
1. Pursuant to Local Rule 6-2, Plaintiff Paul A. Redd, Jr. and Defendant Michael D. Daley, by and through their respective counsel of record, hereby jointly stipulate and respectfully request the Court enter an order as follows:
2. The October 20, 2014, Case Management and Pretrial Order for Jury Trial set the pre-trial conference date on May 12, 2015, and trial on June 8, 2015. (ECF 234.)
3. On November 26, 2014, the Court granted the parties' joint stipulated request to continue the discovery deadlines. (ECF 237.) In the Order, the Court set the following discovery deadlines:
• Non-expert discovery cut off: February 2, 2015
• Opening expert reports: February 2, 2015
• Rebuttal expert reports: February 23, 2015
• Expert discovery cut off: March 9, 2015
4. Since the Court's November 26, 2014 order, the parties have continued to engage in meaningful discussions regarding settlement of this action and scheduling discovery so as not to prejudice their direct settlement discussions.
5. Defendant's counsel recently learned that their expert witness Robert Bruckman, M.D., is not available for the June 8, 2015, trial due to a prior commitment. Dr. Bruckman will be out of the country from May 31, 2015 to June 22, 2015. Dr. Bruckman has confirmed that he would be available to attend and testify at trial the week of June 22, 2015.
6. Accordingly, in order for the parties to explore fully the possibility of settlement of this action, allow the parties to complete discovery (including Plaintiff's taking the deposition of Defendant Daley and conducting a second independent medical examination), and to allow Defendant's expert to appear and testify at trial, the parties' respectfully request that the Court continue the discovery, pre-trial, and trial deadlines as follows:
• Non-expert discovery cut off: March 2, 2015
• Opening expert reports: March 2, 2015
• Rebuttal expert reports: March 23, 2015
• Expert discovery cut off: April 6, 2015
• Last day to hear dispositive motions: May 7, 2015
• Pre-trial Conference: May 26, 2015
• Trial: June 22, 2015
ORDER
On the stipulation of the parties, and good cause appearing therefor,
IT IS ORDERED that the discovery deadlines set in the November 26, 2014, Order (ECF 237) and the trial and pre-trial conference dates set in the October 20, 2014, Case Management and Pretrial Order for Jury Trial (ECF 234) be and hereby are continued as follows:
• Non-expert discovery cut off: March 2, 2015
• Opening expert reports: March 2, 2015
• Rebuttal expert reports: March 23, 2015
• Expert discovery cut off: April 6, 2015
• Last day to hear dispositive motions: May 7, 2015 April 16, 2015
• Pre-trial Conference: May 26, 2015 May 12, 2015
• Trial: June 22, 2015 June 8, 2015
Status conference to be held on 2/5/15 at 10:30 a.m. to discuss trial date. Updated joint status report due 1/29/15.
IT IS SO ORDERED AS MODIFIED.
