Filed: Oct. 30, 2014
Latest Update: Oct. 30, 2014
Summary: JOINT STIPULATION RE REQUEST AND ORDER TO CHANGE TIME PURSUANT TO LOCAL CIVIL RULE 6-2(a) WILLIAM H. ORRICK, District Judge. Subject to the Court's order, pursuant to Civil. L. R. 6-2 and by this stipulation, the parties respectfully request to enlarge the following deadlines previously set pursuant to the Court's Civil Pretrial Order and amendments thereto: Event Current Date Proposed Date Fact Discovery Cut-off October 1, 2014 No Change Fac
Summary: JOINT STIPULATION RE REQUEST AND ORDER TO CHANGE TIME PURSUANT TO LOCAL CIVIL RULE 6-2(a) WILLIAM H. ORRICK, District Judge. Subject to the Court's order, pursuant to Civil. L. R. 6-2 and by this stipulation, the parties respectfully request to enlarge the following deadlines previously set pursuant to the Court's Civil Pretrial Order and amendments thereto: Event Current Date Proposed Date Fact Discovery Cut-off October 1, 2014 No Change Fact..
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JOINT STIPULATION RE REQUEST AND ORDER TO CHANGE TIME PURSUANT TO LOCAL CIVIL RULE 6-2(a)
WILLIAM H. ORRICK, District Judge.
Subject to the Court's order, pursuant to Civil. L. R. 6-2 and by this stipulation, the parties respectfully request to enlarge the following deadlines previously set pursuant to the Court's Civil Pretrial Order and amendments thereto:
Event Current Date Proposed Date
Fact Discovery Cut-off October 1, 2014 No Change
Fact Discovery Cut-off for November 3, 2014 December 3, 2014
Depositions and residual
written compliance
Expert Disclosures and November 15, 2014 December 15, 2014
Initial Reports
Expert rebuttal December 3, 2014 January 5, 2015
Discovery Motions filed by November 14, 2014 December 14, 2014
Motions heard by December 17, 2014 January 16, 2015
Expert discovery cutoff December 31, 2014 February 2, 2015
Pretrial conference March 2, 2015 No Change
Trial date March 30, 2015 No Change
1. Good Cause Exists for Enlargement of Time
The parties reached a settlement in principal of this matter following mediation with Judge Charles McCoy (Ret.) on October 2, 2014. Since the completion of Mediation, the parties are working cooperatively to reduce the settlement to a written agreement. Several drafts have been exchanged, with only a limited number of provisions requiring further discussion and drafting. To avoid legal fees and costs to both sides, and to avoid in part expenditures of public funds in litigation proceedings, continued litigation efforts have been stopped with full attention devoted to concluding settlement discussions and completing settlement documentation. Once done, formal and final reviews will be required, possibly including statutory Brown Act Agenda-action compliance. In the interim, the parties respectfully request that the Court enter the modified schedule as requested above. The parties believe that a further extension of the discovery and motion deadlines of about 30 days will facilitate finalization of the settlement and allow all parties and the Court to avoid unnecessary expenses and to prevent wasting of judicial resources.
2. Previous Time Modifications
Prior to reaching a settlement, discovery and motion deadlines were previously extended by agreement and stipulation to accommodate mediation efforts. The trial date of March 30, 2015, as set in the original Civil Pretrial Order dated March 3, 2014, has not been changed, although the parties may need to address that date in light of the compressed schedule presented.
3. Effect on the Current Schedule in the Case
The requested time modification will change the Court-ordered discovery and motion deadlines as noted above. As the parties have reached a settlement in principal, and to conserve both the Court's and the parties resources, modifications to the trial date have not been requested at this time.
I hereby attest that I have on file all holographic signatures corresponding to any signatures indicated by a conformed signature (/S/) within this e-filed document
IT IS SO STIPULATED.
ORDER
Based on the foregoing stipulation of counsel and good cause appearing therefore, it is HEREBY ORDERED that the following deadlines in this matter will be modified as follows:
a. Fact Discovery Cut-off for Depositions and residual written compliance will be extended from November 3, 2014, to December 3, 2014;
b. The deadline for Expert Disclosures and Initial Reports will be extended from November 15, 2014, to December 15, 2014;
c. The deadline for Expert Rebuttal will be extended from December 3, 2014, to January 5, 2015;
d. The last day for filing motions relating to fact discovery will be extended from November 14, 2014, to December 15, 2014;
e. The last day for hearing motions will be extended from December 17, 2014, to January 14, 2015; and
f. Expert Discovery Cut-off will be extended from December 31, 2014, to February 2, 2015.
PURSUANT TO STIPULATION OF COUNSEL, IT IS SO ORDERED.
