Filed: Dec. 16, 2016
Latest Update: Dec. 16, 2016
Summary: STIPULATION AND ORDER EXTENDING CERTAIN DISCOVERY DEADLINES KANDIS A. WESTMORE , District Judge . It is hereby stipulated, by and through counsel for Plaintiff CHARLES CHRISTOPHER PERKINS, Plaintiff THE LAGUNITAS BREWING COMPANY and TWIN CITY FIRE INSURANCE COMPANY, and Defendant SENTRY EQUIPMENT ERECTORS, INC., that: 1. The parties recently attended a first attempt at Alternative Dispute Resolution (ADR) with Jonathan Lee, Esq. serving as mediator on December 2, 2016. The parties believe
Summary: STIPULATION AND ORDER EXTENDING CERTAIN DISCOVERY DEADLINES KANDIS A. WESTMORE , District Judge . It is hereby stipulated, by and through counsel for Plaintiff CHARLES CHRISTOPHER PERKINS, Plaintiff THE LAGUNITAS BREWING COMPANY and TWIN CITY FIRE INSURANCE COMPANY, and Defendant SENTRY EQUIPMENT ERECTORS, INC., that: 1. The parties recently attended a first attempt at Alternative Dispute Resolution (ADR) with Jonathan Lee, Esq. serving as mediator on December 2, 2016. The parties believe t..
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STIPULATION AND ORDER EXTENDING CERTAIN DISCOVERY DEADLINES
KANDIS A. WESTMORE, District Judge.
It is hereby stipulated, by and through counsel for Plaintiff CHARLES CHRISTOPHER PERKINS, Plaintiff THE LAGUNITAS BREWING COMPANY and TWIN CITY FIRE INSURANCE COMPANY, and Defendant SENTRY EQUIPMENT ERECTORS, INC., that:
1. The parties recently attended a first attempt at Alternative Dispute Resolution (ADR) with Jonathan Lee, Esq. serving as mediator on December 2, 2016. The parties believe that additional non-expert discovery is needed to return to ADR in hopes of pursuing additional good faith efforts to settle this case.
2. Many of the individuals that are to be deposed live outside of California in places such as Virginia and Oregon, which makes the scheduling and attending their depositions difficult to complete by December 23, 2016 as ordered by the Court and previously stipulated to the parties. Some of these individuals were only identified, and their significance ascertained, during the deposition of Defendant Sentry Equipment & Erectors, Inc. Rule 30(b)(6) witness, Doug Weeks, that was taken on November 17, 2016 in Lynchburg, Virginia.
3. In an effort to resume good faith negotiations of this matter and to schedule and attend the depositions in this case, the parties wish to enter into another stipulation to extend non-expert discovery as well as other deadlines that could be affected by the continuance of non-expert discovery.
4. Summary of current and proposed dates:
Date/Deadline Current Date Proposed Date
Last Day to Hear Dispositive Motions April 6, 2017 April 14, 2017
Close of Expert Discovery March 24, 2017 April 3, 2017
Rebuttal Expert Disclosure/Reports March 10, 2017 March 24, 2017
Defendant's Expert Disclosure/Reports February 24, 2017 March 10, 2017
Plaintiffs' Expert Disclosure/Reports January 20, 2017 February 10, 2017
Non-expert Discovery Cut-off December 23, 2016 January 13, 2017
ADR Completion November 30, 2016 Completed
5. The parties stipulate that all other dates in the April 29, 2016 Case Management and Pretrial Order for Jury Trial can remain unchanged.
IT IS SO STIPULATED.
[PROPOSED] ORDER
Pursuant to the above stipulation of the parties and good cause appearing, the April 29, 2016 Case Management and Pretrial Order for Jury Trial is modified to reflect the Proposed Dates, set forth above, AS MODIFIED.
