Filed: Nov. 15, 2012
Latest Update: Nov. 15, 2012
Summary: JOINT STIPULATION TO AMEND DISCOVERY DEADLINES; [PROPOSED] ORDER RICHARD SEEBORG, District Judge. STIPULATION Plaintiff Theresa Allen and defendant TestAmerica Laboratories, Inc., by and through their representative counsel of record, hereby stipulate as follows: 1. On June 6, 2012, the Court issued the Case Management Scheduling Order (Docket No. 18), which set the following discovery deadlines: a. November 30, 2012, for the parties to complete all non-expert discovery; b. December
Summary: JOINT STIPULATION TO AMEND DISCOVERY DEADLINES; [PROPOSED] ORDER RICHARD SEEBORG, District Judge. STIPULATION Plaintiff Theresa Allen and defendant TestAmerica Laboratories, Inc., by and through their representative counsel of record, hereby stipulate as follows: 1. On June 6, 2012, the Court issued the Case Management Scheduling Order (Docket No. 18), which set the following discovery deadlines: a. November 30, 2012, for the parties to complete all non-expert discovery; b. December ..
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JOINT STIPULATION TO AMEND DISCOVERY DEADLINES; [PROPOSED] ORDER
RICHARD SEEBORG, District Judge.
STIPULATION
Plaintiff Theresa Allen and defendant TestAmerica Laboratories, Inc., by and through their representative counsel of record, hereby stipulate as follows:
1. On June 6, 2012, the Court issued the Case Management Scheduling Order (Docket No. 18), which set the following discovery deadlines:
a. November 30, 2012, for the parties to complete all non-expert discovery;
b. December 7, 2012, for the parties to complete their expert disclosures; and
c. December 21, 2012, for the parties to complete all expert discovery.
2. Presently, the parties have several outstanding discovery disputes relating to non-expert discovery that may result in motion practice; in addition, the parties are attempting to schedule several previously noticed depositions of non-expert witnesses.
3. On November 13, 2012, the parties met and conferred regarding the status of the case and agreed to engage in good faith settlement discussions, including through private mediation in early or mid-December, 2012. In order to facilitate these settlement discussions and avoid unnecessary motion practice for the Court and the parties, should the case settle, the parties ask the Court to continue the discovery deadlines as set forth in the June 6, 2012, Case Management Scheduling Order.
4. The parties ask the Court to amend the applicable discovery deadlines as follows:
a. January 18, 2013, as the new deadline by which the parties must file any motion to resolve outstanding disputes regarding non-expert discovery, and complete any previously noticed non-expert deposition;
b. January 18, 2013, as the new deadline by which the parties must complete their expert disclosures; and
c. February 8, 2013, as the new deadline by which the parties must complete all expert discovery.
5. Nothing in this stipulation will affect the February 21, 2013, deadline by which the Court must hear all pretrial motions; the May 2, 2013, deadline by which the parties must file their Joint Pretrial Statement; the May 16, 2013, pretrial conference, or the May 28, 2013, commencement date for trial.
6. The parties respectfully request that the Court grant this joint stipulation so that they might attempt to resolve this case without prejudicing further discovery.
ORDER
On the stipulation of the parties, and good cause appearing therefor,
The Court GRANTS the Joint Stipulation to Amend Discovery Deadlines. The dates set forth in the June 6, 2012, Case Management Scheduling Order (Docket No. 18), are modified as follows:
1. January 18, 2013, is the new deadline by which the parties must file any motion to resolve outstanding disputes regarding non-expert discovery, and complete any previously noticed non-expert deposition;
2. January 18, 2013, is the new deadline by which the parties must complete their expert disclosures; and
3. February 8, 2013, is the new deadline by which the parties must complete all expert discovery.
No other dates set forth in the Case Management Scheduling Order are modified.
IT IS SO ORDERED.
