Filed: Nov. 17, 2015
Latest Update: Nov. 17, 2015
Summary: STIPULATED REQUEST AND [PROPOSED] ORDER MODIFYING CASE MANAGEMENT SCHEDULE SUSAN ILLSTON , Magistrate Judge . The undersigned counsel, on behalf of Plaintiffs Charles Ridgeway, Jaime Famoso, Joshua Harold, Richard Byers, Dan Thatcher, Nino Pagtama, Willie Franklin, Tim Opitz, Farris Day, Karl Merhoff, and Micheal Krohn ("Plaintiffs") and Defendant Wal-Mart Stores, Inc. ("Wal-Mart," and collectively, with Plaintiffs, the "Parties"), hereby stipulate as follows: RECITALS WHEREAS the Court
Summary: STIPULATED REQUEST AND [PROPOSED] ORDER MODIFYING CASE MANAGEMENT SCHEDULE SUSAN ILLSTON , Magistrate Judge . The undersigned counsel, on behalf of Plaintiffs Charles Ridgeway, Jaime Famoso, Joshua Harold, Richard Byers, Dan Thatcher, Nino Pagtama, Willie Franklin, Tim Opitz, Farris Day, Karl Merhoff, and Micheal Krohn ("Plaintiffs") and Defendant Wal-Mart Stores, Inc. ("Wal-Mart," and collectively, with Plaintiffs, the "Parties"), hereby stipulate as follows: RECITALS WHEREAS the Court h..
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STIPULATED REQUEST AND [PROPOSED] ORDER MODIFYING CASE MANAGEMENT SCHEDULE
SUSAN ILLSTON, Magistrate Judge.
The undersigned counsel, on behalf of Plaintiffs Charles Ridgeway, Jaime Famoso, Joshua Harold, Richard Byers, Dan Thatcher, Nino Pagtama, Willie Franklin, Tim Opitz, Farris Day, Karl Merhoff, and Micheal Krohn ("Plaintiffs") and Defendant Wal-Mart Stores, Inc. ("Wal-Mart," and collectively, with Plaintiffs, the "Parties"), hereby stipulate as follows:
RECITALS
WHEREAS the Court has set pre-trial deadlines in its Second Pretrial Preparation Order (Dkt. No. 213) and had previously set deadlines in its Pretrial Preparation Order (Dkt. No. 174);
WHEREAS the parties have worked diligently to resolve discovery and deposition issues in the timing provided by that Order;
WHEREAS Plaintiffs' counsel are currently in the midst of a three month class action trial in another lawsuit that will affect the parties' ability to complete agreed upon discovery and depositions as scheduled, particularly given the time constraints of the coming retail blackout holiday period where many Wal-Mart employees will be unavailable because of business constraints; and
WHEREAS the parties believe they have identified the remaining discovery to be completed and believe the new deadlines will allow an orderly completion of the same.
STIPULATION
Accordingly, the parties now jointly stipulate and respectfully request that this Court order the following changes to the existing schedule:
Event Current Date Proposed New Date
Expert Designation October 19, 2015 June 17, 2016
Expert Rebuttal October 28, 2015 July 18, 2016
Dispositive Motions January 15, 2016 On or before July 15, 2016
Oppositions to Dispositive Motions January 29, 2016 Three weeks to oppose
Replies In Support of Motions February 5, 2016 Two weeks to reply
Discovery Cutoff (Expert and Non-Expert) December 3, 2015 August 19, 2016
Pretrial Conference April 12, 2016 September 2, 2016
Trial April 25, 2016 September 16, 2016
Pursuant to Local Rule 6-2(a), the declarations of Daniel M. Kopfman and Jesse A. Cripps in support of this stipulation are filed herewith.
IT IS SO STIPULATED.
[PROPOSED] ORDER
Pursuant to the above stipulation, the Stipulation and Order regarding the case management schedule is approved.
