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TAM v. DONAHOE, C12-05858 MEJ. (2014)

Court: District Court, N.D. California Number: infdco20140128739 Visitors: 13
Filed: Jan. 27, 2014
Latest Update: Jan. 27, 2014
Summary: STIPULATION TO EXTEND CASE MANAGEMENT DEADLINES MARIA-ELENA JAMES, Magistrate Judge. The parties hereby file this stipulation requesting extension of the discovery deadlines, dispositive motions filing deadline, and pretrial conference and trial dates in the above-captioned case. An extension is required due to the difficulty in finding a mutually convenient date and time for plaintiff's deposition and to allow additional time for completion of discovery and ADR following the plaintiff's depos
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STIPULATION TO EXTEND CASE MANAGEMENT DEADLINES

MARIA-ELENA JAMES, Magistrate Judge.

The parties hereby file this stipulation requesting extension of the discovery deadlines, dispositive motions filing deadline, and pretrial conference and trial dates in the above-captioned case. An extension is required due to the difficulty in finding a mutually convenient date and time for plaintiff's deposition and to allow additional time for completion of discovery and ADR following the plaintiff's deposition.

1. Around November 1, 2013, the parties discussed the scheduling of depositions in this matter. Defendant's counsel asked to schedule plaintiff's deposition. As plaintiff was out of the country and STIP. TO CONTINUE CMC DATES C12-05858 MEJ unavailable in November and part of December, and the deadline to amend pleadings was December 23, 2013, the parties discussed setting plaintiff's deposition for January 13, 2014. However, on December 23, 2013, plaintiff's counsel notified defendant's counsel that the earliest date for which plaintiff and plaintiff's counsel would be available for deposition was February 2014. The parties have since agreed to a mutually convenient date for the plaintiff's deposition, February 12, 2014. In agreeing to February 12, 2014, for the plaintiff's deposition, defendant's counsel asked that plaintiff stipulate move the discovery and dispositive motions deadlines to allow time for additional fact and expert discovery as well as the scheduling of an ADR session following plaintiff's deposition.

2. The parties have previously stipulated to move the dispositive motions filing deadline from April 17, 2014 to May 15, 2014 to accommodate defendant's counsel unavailability from April 5, 2014 through April 24, 2014 due to her wedding and honeymoon from April 5 through April 24, 2014.

3. Currently, the case management deadlines in the case are as follows:

a. Disclosure of Expert Witnesses Due: February 21, 2014 b. Disclosure of Rebuttal Expert Witnesses Due: March 3, 2014 c. Fact Discovery Cut-Off: March 18, 2014 d. Filing Deadline for Dispositive Motions: May 15, 2014 e. Dispositive Motions Hearing Date: June 19, 2014 f. Initial Pre-trial Conference: August 28, 2014 at 10:00 a.m. g. Final Pre-trial Conference: September 25, 2014 at 10:00 a.m. h. Trial: October 6, 2014

4. For the reasons discussed above, the parties hereby stipulate and agree, subject to the Court's approval, to the extend the case management deadlines as follows:

a. Disclosure of Expert Witnesses Due: June 16, 2014 b. Disclosure of Rebuttal Expert Witnesses Due: June 26, 2014 c. Fact Discovery Cut-Off: July 11, 2014 d. Filing Deadline for Dispositive Motions: July 24, 2014 e. Dispositive Motions Hearing Date: August 28, 2014 f. Initial Pre-trial Conference: October 30, 2014 at 10:00 a.m. g. Final Pre-trial Conference: November 26, 2014 at 10:00 a.m. h. Trial: December 8, 2014

IT IS SO STIPULATED.

AMENDED [PROPOSED] ORDER

Pursuant to the parties' stipulation, and good cause having been shown, the case management dates in the above-captioned case are set as follows:

Disclosure of Expert Witnesses Due: June 16, 2014 Disclosure of Rebuttal Expert Witnesses Due: June 26, 2014 Fact Discovery Cut-Off: July 11, 2014 Filing Deadline for Dispositive Motions: July 24, 2014 Dispositive Motions Hearing Date: August 28, 2014 Initial Pre-trial Conference: October 30, 2014 at 10:00 a.m. Final Pre-trial Conference: November 26,20 2014 at 10:00 a.m. Trial: December 8, 2014

IT IS SO ORDERED.

Source:  Leagle

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