Filed: Mar. 26, 2015
Latest Update: Mar. 26, 2015
Summary: AMENDED STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINES JACQUELINE SCOTT CORLEY , Magistrate Judge . 1. On January 27, 2014, the Court issued a Pretrial Order setting the deadline to complete private ADR on March 27, 2015 and set a Further Case Management Conference for May 21, 2015. 2. The parties are attempting in good faith to resolve this matter and have agreed to mediate the case with the Honorable Ellen James of JAMS. Due to defense counsel's trial schedule, the parties n
Summary: AMENDED STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINES JACQUELINE SCOTT CORLEY , Magistrate Judge . 1. On January 27, 2014, the Court issued a Pretrial Order setting the deadline to complete private ADR on March 27, 2015 and set a Further Case Management Conference for May 21, 2015. 2. The parties are attempting in good faith to resolve this matter and have agreed to mediate the case with the Honorable Ellen James of JAMS. Due to defense counsel's trial schedule, the parties ne..
More
AMENDED STIPULATION AND [PROPOSED]ORDER TO CONTINUE DEADLINES
JACQUELINE SCOTT CORLEY, Magistrate Judge.
1. On January 27, 2014, the Court issued a Pretrial Order setting the deadline to complete private ADR on March 27, 2015 and set a Further Case Management Conference for May 21, 2015.
2. The parties are attempting in good faith to resolve this matter and have agreed to mediate the case with the Honorable Ellen James of JAMS. Due to defense counsel's trial schedule, the parties need additional time to mediate and have scheduled mediation for June 23, 2015.
3. The parties agree that judicial economy is served by continuing the current mediation completion deadline to June 23, 2015 and continuing the Further Case Management Conference to July 20, 2015, or a date thereafter that is convenient for the Court.
4. The parties have also agreed on a limited discovery plan prior to mediation. Since the current fact discovery cut-off date is July 27th, 2015, in the event the case does not settle at mediation, the parties anticipate requiring more time to complete discovery and other case matters. Thus, the parties propose the following extensions to the deadlines set by the Court's October 30, 2014 Pretrial Order:
Current Deadline Proposed Deadline
Deadline to Complete ADR March 27, 2015 June 23, 2015
Further Case Management May 21, 2015 July 20, 2015
Conference July 30, 2015
Fact Discovery Cut-off July 27, 2015 September 11, 2015
Expert Witness Disclosures August 24, 2015 September 25, 2011
Rebuttal Expert Disclosures September 7, 2015 October 2, 2015
Deadline to Hear Dispositive September 24, 2015 October 16, 2015
Motions
5. The parties do not propose any extensions to the current trial date or any of the pretrial deadlines set by the Court in the October 30, 2014 Pretrial Order.
6. THEREFORE, the parties hereto stipulate and agree, and request, that the Court enter an Order continuing deadlines as proposed in the table above.
IT IS SO STIPULATED.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
