Filed: Feb. 19, 2015
Latest Update: Feb. 19, 2015
Summary: STIPULATION AND [PROPOSED] ORDER REGARDING (1) THREE-WEEK EXTENSION OF 2/27/15 NON-EXPERT DISCOVERY DEADLINE FOR PURPOSES OF TWO SPECIFIC DEPOSITIONS ONLY, AND (2) THREE-WEEK EXTENSION OF EXPERT-RELATED DEADLINES OF 2/27/15, 3/18/15, AND 4/10/15 EDWARD M. CHEN, District Judge. STIPULATION The Court's order dated January 23, 2015 (Docket No. 799) set certain pre-trial dates, including, as relevant here: • A non-expert discovery deadline of February 27, 2015. • An expert report deadline
Summary: STIPULATION AND [PROPOSED] ORDER REGARDING (1) THREE-WEEK EXTENSION OF 2/27/15 NON-EXPERT DISCOVERY DEADLINE FOR PURPOSES OF TWO SPECIFIC DEPOSITIONS ONLY, AND (2) THREE-WEEK EXTENSION OF EXPERT-RELATED DEADLINES OF 2/27/15, 3/18/15, AND 4/10/15 EDWARD M. CHEN, District Judge. STIPULATION The Court's order dated January 23, 2015 (Docket No. 799) set certain pre-trial dates, including, as relevant here: • A non-expert discovery deadline of February 27, 2015. • An expert report deadline ..
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STIPULATION AND [PROPOSED] ORDER REGARDING (1) THREE-WEEK EXTENSION OF 2/27/15 NON-EXPERT DISCOVERY DEADLINE FOR PURPOSES OF TWO SPECIFIC DEPOSITIONS ONLY, AND (2) THREE-WEEK EXTENSION OF EXPERT-RELATED DEADLINES OF 2/27/15, 3/18/15, AND 4/10/15
EDWARD M. CHEN, District Judge.
STIPULATION
The Court's order dated January 23, 2015 (Docket No. 799) set certain pre-trial dates, including, as relevant here:
• A non-expert discovery deadline of February 27, 2015.
• An expert report deadline of February 27, 2015.
• A rebuttal expert report deadline of March 18, 2015.
• An expert discovery deadline of April 10, 2015.
The parties have announced intentions to take certain depositions, including two that for various reasons cannot be practically implemented within the February 27, 2015 deadline: (1) Plaintiff's 30(b)(6) Notice of Deposition, covering sixteen separate promotion decisions across the country, and (2) Elaine Sasaki's deposition. Expert reports may rely upon the results of these depositions.
Counsel for Plaintiff Elaine Sasaki and Defendant Costco Wholesale Corporation therefore stipulate as follows:
1. The non-expert discovery deadline now set for February 27, 2015, shall be re-set to March 20, 2015 for the limited purpose of completing the depositions associated with Plaintiff's Notice of Deposition Pursuant to 30(b)(6) dated January 28, 2015 and Plaintiff Elaine Sasaki's deposition.
2. The expert report deadline now set for February 27, 2015, shall be re-set to March, 20 2015.
3. The rebuttal expert report deadline now set for March 18, 2015, shall be re-set to April 8, 2015.
4. The expert discovery deadline now set for April 10, 2015, shall be re-set to May 1, 2015.
The order stipulated to herein would have no effect on the June 30, 2015 pre-trial conference date or the July 27, 2015 trial date.
IT IS SO STIPULATED.
The Court orders as follows:
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED:
1. The non-expert discovery deadline now set for February 27, 2015, shall be re-set to March 20, 2015.
2. The expert report deadline now set for February 27, 2015, shall be re-set to March, 20 2015.
3. The rebuttal expert report deadline now set for March 18, 2015, shall be re-set to April 8, 2015.
4. The expert discovery deadline now set for April 10, 2015, shall be re-set to May 1, 2015.
