Filed: May 15, 2019
Latest Update: May 15, 2019
Summary: STIPULATION EXTENDING EXPERT WITNESS DEADLINES; ORDER HAYWOOD S. GILLIAM, JR. , District Judge . Pursuant to Northern District Rule 6-2, and subject to the Court's approval, Plaintiffs Alex Ang and Lynne Streit (collectively, "Plaintiffs") and defendant Bimbo Bakeries U.S.A., Inc. ("Defendant") (collectively "the Parties") respectfully submit the following Stipulation and proposed Order. WHEREAS, the Parties are actively engaged in productive settlement negotiations; WHEREAS, the Court ha
Summary: STIPULATION EXTENDING EXPERT WITNESS DEADLINES; ORDER HAYWOOD S. GILLIAM, JR. , District Judge . Pursuant to Northern District Rule 6-2, and subject to the Court's approval, Plaintiffs Alex Ang and Lynne Streit (collectively, "Plaintiffs") and defendant Bimbo Bakeries U.S.A., Inc. ("Defendant") (collectively "the Parties") respectfully submit the following Stipulation and proposed Order. WHEREAS, the Parties are actively engaged in productive settlement negotiations; WHEREAS, the Court has..
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STIPULATION EXTENDING EXPERT WITNESS DEADLINES; ORDER
HAYWOOD S. GILLIAM, JR., District Judge.
Pursuant to Northern District Rule 6-2, and subject to the Court's approval, Plaintiffs Alex Ang and Lynne Streit (collectively, "Plaintiffs") and defendant Bimbo Bakeries U.S.A., Inc. ("Defendant") (collectively "the Parties") respectfully submit the following Stipulation and proposed Order.
WHEREAS, the Parties are actively engaged in productive settlement negotiations;
WHEREAS, the Court has ordered the Parties to schedule a teleconference with the ADR Unit and to advise the Court no later than May 17, 2019 as to the scheduled date;
WHEREAS, the deadline to exchange opening expert reports is May 14, 2019;
WHEREAS, counsel for the Parties believe that a three week extension of the expert witness deadlines will aid settlement negotiations and enable the parties to avoid significant expense;
WHEREAS, there have been no previous extensions of the pretrial schedule in this action;
WHEREAS, a three week extension of the expert witness deadlines will have no effect on the remainder of the schedule in this action;
The Parties stipulate to the following three week extension of each expert witness deadline, and respectfully request that the Court enter the accompanying proposed Order:
Deadline to exchange opening expert reports June 4, 2019
Deadline to exchange rebuttal expert reports July 5, 2019
Expert discovery deadline August 5, 2019
Dated: May 14, 2019
/s/PierceGore
Ben F. Pierce Gore (SBN 128515)
PRATT & ASSOCIATES
1871 The Alameda, Suite 425
San Jose, CA 95126
Telephone: (408) 429-6506
Fax: (408) 369-0752
pgore@prattattorneys.com
Attorneys for Plaintiffs
/s/Mark C. Goodman
Mark C. Goodman (Bar No. 154692)
BAKER & McKENZIE LLP
Two Embarcadero Center, Suite 1100
San Francisco, California 94111
Telephone: (415) 576-3000
Facsimile: (415) 576-3099
mark.goodman@bakermckenzie.com
Attorneys for Defendant
ECF ATTESTATION
I, Pierce Gore, am the ECF User whose ID and password are being used to file the following: STIPULATION AND [PROPOSED] ORDER. In compliance with General Order 45, X.B., I hereby attest that Mark C. Goodman has concurred in this filing.
May 14, 2019 Pierce Gore
ORDER
Pursuant to Stipulation of the parties, and good cause appearing therefor, the Court hereby approves the Stipulation, and enters it as the Order of the Court.