Filed: Jan. 31, 2019
Latest Update: Jan. 31, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL AND ASSOCIATED DEADLINES ELIZABETH D. LAPORTE , Magistrate Judge . Pursuant to Fed. R. Civ. P. 6(b)(1) and Civil L.R. 6-1, 6-2, and 7-12, the parties ("Parties") in related case numbers 17CV0851-EDL and 17CV1232-EDL hereby submit, for the Court's consideration and approval, this Joint Stipulation and Order Continuing Trial and Associated Deadlines as follows: WHEREAS, on January 15, 2019 the Parties attended a mediation in the a
Summary: JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL AND ASSOCIATED DEADLINES ELIZABETH D. LAPORTE , Magistrate Judge . Pursuant to Fed. R. Civ. P. 6(b)(1) and Civil L.R. 6-1, 6-2, and 7-12, the parties ("Parties") in related case numbers 17CV0851-EDL and 17CV1232-EDL hereby submit, for the Court's consideration and approval, this Joint Stipulation and Order Continuing Trial and Associated Deadlines as follows: WHEREAS, on January 15, 2019 the Parties attended a mediation in the ab..
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JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL AND ASSOCIATED DEADLINES
ELIZABETH D. LAPORTE, Magistrate Judge.
Pursuant to Fed. R. Civ. P. 6(b)(1) and Civil L.R. 6-1, 6-2, and 7-12, the parties ("Parties") in related case numbers 17CV0851-EDL and 17CV1232-EDL hereby submit, for the Court's consideration and approval, this Joint Stipulation and Order Continuing Trial and Associated Deadlines as follows:
WHEREAS, on January 15, 2019 the Parties attended a mediation in the above titled related cases, which was unsuccessful.
WHEREAS, at mediation it was revealed that another mediation could be more productive after the completion of third party discovery, particularly discovery from third parties that may be obligated to indemnify Defendants and carry relevant insurance.
WHEREAS, the parties have been and are diligently seeking to further third party discovery and wish to continue such efforts in order to foster a potentially successful second mediation.
WHEREAS, some third parties are resisting such discovery and it is possible that motion practice will be necessary.
WHEREAS, given the additional discovery that needs to take place prior to the next mediation, the Parties agree and stipulate to continue trial and all associated deadlines by approximately sixty (60) days as follows or as deemed appropriate by the Court:
Event Current Extension (60 days-with
Deadline the exception of
the first deadline)
Deadline to file a motion to add claims or 1/30/19 5/30/191
parties
Close of fact discovery 5/28/19 7/26/19
Initial expert disclosures 6/4/19 8/2/19
Rebuttal expert disclosures 6/18/19 8/16/19
Close of expert discovery 7/1/19 8/30/19
Deadline for Defendants' dispositive motion 7/9/19 9/6/19
Deadline for Plaintiffs to file combined 7/30/19 9/27/19
opposition and cross-motion brief
Deadline for Defendants' combined reply and 8/20/19 10/18/19
opposition brief
Deadline for Plaintiffs' reply to the cross-motion 9/3/19 11/1/19
brief
Hearing on dispositive motions 9/24/19 11/26/19
Meet and confer re joint pretrial statement, Not specified in 1/17/20
exchange of pretrial materials, and settlement Order
(at least 30 days before pretrial conference)
Deadline for: Not specified in 1/29/20
Order
-Joint pretrial statement
-Trial briefs
-Motions in limine
-Daubert motions
-Proposed voir dire questions
-Jury instructions
-Verdict forms
-Deposition transcript designations and other
discovery materials to be used at trial
-Exhibit setting forth expert qualifications and
experience
-Exhibit lists
-Exchange of exhibits, with copy to chambers
(at least 20 days before pretrial conference)
Deadline for: Not specified in 2/7/20
Order
-Objections to exhibits or deposition excerpts
or other discovery materials
-objections to non-expert witnesses
-Objections to proposed voir dire questions
-Jury instructions
-Verdict forms
-Oppositions to motions in limine
(at least 10 days before pretrial conference)
Pretrial conference 12/17/19 2/18/20
Jury trial (7 days) 1/13/20 3/16/20
WHEREAS, in case number 17CV0851-EDL the Parties have previously stipulated to and requested the Court issue an order extending the motion to dismiss briefing deadlines and hearing dates, as well as the date for the Initial Case Management Conference in this action (Dkts. 12, 15, 27, and 38), and this Court granted those stipulated requests (Dkts. 13, 18, 28, and 39).
WHEREAS, in case number 17CV1232-EDL the Parties have previously stipulated to and requested the Court issue an order extending the motion to dismiss briefing deadlines and hearing dates, as well as the date for the Initial Case Management Conference in this action (Dkts. 12, 17, and 34), and this Court granted those stipulated requests (Dkts. 14, 18, 25, and 35).
THEREFORE, subject to the Court's approval, the Parties hereby Stipulate to an Order by the Court that the trial date currently set for January 13, 2020 and all associated deadlines be continued by approximately sixty (60) days.2
[PROPOSED] ORDER
The Court, having reviewed the Parties' Joint Stipulation and [Proposed] Order Continuing Trial Date and Deadlines, orders as follows:
The trial date currently set for January 13, 2020 and all associated deadlines be continued as follows:
Event Current Deadline Extension
Deadline to file a motion to add claims or 1/30/19 5/30/19
parties
Close of fact discovery 5/28/19 7/26/19
Initial expert disclosures 6/4/19 8/2/19
Rebuttal expert disclosures 6/18/19 8/16/19
Close of expert discovery 7/1/19 8/30/19
Deadline for Defendants' dispositive motion 7/9/19 9/6/19
Deadline for Plaintiffs to file combined 7/30/19 9/27/19
opposition and cross-motion brief
Deadline for Defendants' combined reply and 8/20/19 10/18/19
opposition brief
Deadline for Plaintiffs' reply to the cross-motion 9/3/19 11/1/19
brief
Hearing on dispositive motions 9/24/19 11/26/19
Meet and confer re joint pretrial statement, Not specified in 1/17/20
exchange of pretrial materials, and settlement Order
(at least 30 days before pretrial conference)
Deadline for: Not specified in 1/29/20
Order
-Joint pretrial statement
-Trial briefs
-Motions in limine
-Daubert motions
-Proposed voir dire questions
-Jury instructions
-Verdict forms
-Deposition transcript designations and other
discovery materials to be used at trial
-Exhibit setting forth expert qualifications and
experience
-Exhibit lists
-Exchange of exhibits, with copy to chambers
(at least 20 days before pretrial conference)
Deadline for: Not specified in 2/7/20
Order
-Objections to exhibits or deposition excerpts
or other discovery materials
-objections to non-expert witnesses
-Objections to proposed voir dire questions
-Jury instructions
-Verdict forms
-Oppositions to motions in limine
(at least 10 days before pretrial conference)
Pretrial conference 12/17/19 2/18/20
Jury trial (7 days) 1/13/20 3/16/20
IT IS ORDERED.