Filed: Jan. 11, 2013
Latest Update: Jan. 11, 2013
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES ELIZABETH D. LAPORTE, Magistrate Judge. STIPULATION IT IS HEREBY STIPULATED by and between plaintiff Sterling Savings Bank ("Plaintiff") and defendant Lisa Poulsen, aka Norman Poulsen ("Defendant"), through their respective counsel of record, as follows: WHEREAS, this Court entered a Case Management and Pretrial Order for Jury Trial for this action on October 3, 2013, which set forth the following dates and deadlines: 1. Jury trial t
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES ELIZABETH D. LAPORTE, Magistrate Judge. STIPULATION IT IS HEREBY STIPULATED by and between plaintiff Sterling Savings Bank ("Plaintiff") and defendant Lisa Poulsen, aka Norman Poulsen ("Defendant"), through their respective counsel of record, as follows: WHEREAS, this Court entered a Case Management and Pretrial Order for Jury Trial for this action on October 3, 2013, which set forth the following dates and deadlines: 1. Jury trial to..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES
ELIZABETH D. LAPORTE, Magistrate Judge.
STIPULATION
IT IS HEREBY STIPULATED by and between plaintiff Sterling Savings Bank ("Plaintiff") and defendant Lisa Poulsen, aka Norman Poulsen ("Defendant"), through their respective counsel of record, as follows:
WHEREAS, this Court entered a Case Management and Pretrial Order for Jury Trial for this action on October 3, 2013, which set forth the following dates and deadlines:
1. Jury trial to begin on June 17, 2013;
2. All non-expert discovery to be completed no later than February 1, 2013;
3. Initial expert disclosures to be made no later than March 15, 2013;
4. Rebuttal expert disclosures to be made no later than March 29, 2013;
5. All expert discovery to be completed no later than April 16, 2013;
6. The last day to file a motion, or stipulation and proposed order, to join other parties or to amend the pleadings was January 2, 2013;
7. The last day for hearing dispositive motions is March 19, 2013;
8. Mediation proceedings are to be completed by December 26, 2012 (within 90 days of the order), or as soon thereafter as possible; and
9. A pretrial conference is to be held on May 28, 2013;
WHEREAS, both Plaintiff and Defendant have been diligent in conducting discovery, and agree that additional time is needed to complete written discovery and depositions necessary for the adjudication of this case;
WHEREAS, the parties commenced mediation on December 4, 2012, and are currently engaged in ongoing mediation and settlement discussions, and agree that it is in the best interest of both Plaintiff and Defendant to undergo further settlement negotiations with the mediator;
WHEREAS, the parties agree that extending the deadlines for discovery, dispositive motions and trial by approximately sixty (60) days would benefit the parties' settlement discussions;
NOW, THEREFORE, the parties hereby agree and stipulate:
1. Plaintiff and Defendant agree and stipulate that the current schedule for this case, as set forth in this Court's Case Management and Pretrial Order for Jury Trial filed October 3, 2012, be modified as follows:
a. Jury trial is to begin on October 7, 2013;
b. All non-expert discovery must be completed no later than April 1, 2013;
c. Initial expert disclosures must be made no later than May 17, 2013;
d. Rebuttal expert disclosures must be made no later than May 31, 2013;
e. All expert discovery must be completed no later than June 30, 2013;
f. The last day to file a motion, or stipulation and proposed order, to join other parties or to amend the pleadings is March 1, 2013;
g. The last day for hearing dispositive motions is July 15, 2013;
h. Mediation proceedings are to be completed by March 1, 2013, or as soon thereafter as possible; and
i. A pretrial conference is to be held on September 16, 2013;
2. The parties respectfully request that the Court modify the time frames set forth in the aforementioned Case Management and Pretrial Order to reflect the dates and deadlines provided in the preceding paragraph;
3. Plaintiff and Defendant have reviewed, agree and consent to the entry of the Proposed Order to Extend Deadlines.
IT IS SO STIPULATED:
DATED: January 7, 2013 SHUMENER, ODSON & OH LLP
By: ______________________
John D. Spurling
Attorneys for Plaintiff
STERLING SAVINGS BANK
DATED: January 7, 2013 DOHERTY GEORGESON LLP
By: _______________________
Adamont N. Georgeson
Attorneys for Defendant
LISA POULSEN
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED:
1. The current schedule for this case, as set forth in the Case Management and Pretrial Order for Jury Trial entered October 3, 2012, shall be modified as follows:
a. Jury trial is to begin on October 7, 2013;
b. All non-expert discovery must be completed no later than April 1, 2013;
c. Initial expert disclosures must be made no later than May 17, 2013;
d. Rebuttal expert disclosures must be made no later than May 31, 2013;
e. All expert discovery must be completed no later than June 30, 2013;
f. The last day to file a motion, or stipulation and proposed order, to join other parties or to amend the pleadings is March 1, 2013;
g. The last day for hearing dispositive motions is July 15, 2013;
h. Mediation proceedings are to be completed by March 1, 2013, or as soon thereafter as possible; and
i. A pretrial conference is to be held on September 16, 2013;
IT IS SO ORDERED.
