Filed: Feb. 06, 2015
Latest Update: Feb. 06, 2015
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES AS MODIFIED VINCE CHHABRIA, District Judge. WHEREAS, Plaintiff Jackie Arnett filed her complaint for damages naming only Defendants Whitney Equipment LLC ("Whitney") and Seaside Transportation Services, LLC ("STS") in Alameda County Superior Court on March 1, 2013. WHEREAS defendants Whitney and STS removed this case to the Northern District on April 12, 2013. WHEREAS on September 13, 2013, Plaintiff filed a First Amended Complaint a
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES AS MODIFIED VINCE CHHABRIA, District Judge. WHEREAS, Plaintiff Jackie Arnett filed her complaint for damages naming only Defendants Whitney Equipment LLC ("Whitney") and Seaside Transportation Services, LLC ("STS") in Alameda County Superior Court on March 1, 2013. WHEREAS defendants Whitney and STS removed this case to the Northern District on April 12, 2013. WHEREAS on September 13, 2013, Plaintiff filed a First Amended Complaint ad..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES AS MODIFIED
VINCE CHHABRIA, District Judge.
WHEREAS, Plaintiff Jackie Arnett filed her complaint for damages naming only Defendants Whitney Equipment LLC ("Whitney") and Seaside Transportation Services, LLC ("STS") in Alameda County Superior Court on March 1, 2013.
WHEREAS defendants Whitney and STS removed this case to the Northern District on April 12, 2013.
WHEREAS on September 13, 2013, Plaintiff filed a First Amended Complaint adding defendant Shanghai Zhenhua Heavy Industries Co., Ltd. (erroneously sued as Shanghai Zhenhua Port Machinery Co., Ltd., hereinafter "ZPMC".)
WHEREAS Plaintiff filed as Second Amended Complaint on November 4, 2013 in response to ZPMC's motion to dismiss Plaintiff's First Amended Complaint.
WHEREAS ZPMC filed a motion to dismiss Plaintiff's Second Amended Complaint, which was granted in part and denied in part on January 13, 2014.
WHEREAS The Court granted Plaintiff leave to amend her negligence allegations in order to clarify what conduct each defendant has allegedly engaged in that supports each of the theories underlying her negligence causes of action.
WHEREAS Plaintiff filed her Third Amended Complaint on February 3, 2014, and parties responded.
WHEREAS the Court set a Pre-trial Scheduling Order on April 1, 2014.
WHEREAS the Court amended the Pre-trial Scheduling Order on October 28, 2014, and ordered parties to complete private mediation by January 30, 2015.
WHEREAS parties completed mediation on January 26, 2015.
WHEREAS parties now request an extension for expert rebuttal reports, to complete expert depositions and discovery, and to file summary judgment motions in order to accommodate a further private mediation agreed to by parties and scheduled for February 9, 2015.
NOW THEREFORE, IT IS STIPULATED by and between the parties, subject to the approval of the Court pursuant to Local Rule 6-2, to extend discovery deadlines set in the case schedule (Dkt. Nos. 69, 84) as follows:
EVENT CURRENT DEADLINE REQUESTED
EXTENSION DATE
Expert Rebuttal February 2, 2015 February 16, 2015
Close of Expert Discovery March 13, 2015 April 3, 2015
Dispositive Motions Heard by May 6, 2015 May 27, 2015
PURSUANT TO STIPULATION, IT IS SO ORDERED.
