Don Henley et al v. Charles S Devore et al

Filing 44

STIPULATION to Continue DATE TO EXCHANGE ANY REBUTTAL EXPERT WITNESS DISCLOSURES, IF ANY, ALONG WITH ALL NONPUBLIC MATERIALS RELIED UPON BY REBUTTAL EXPERTS THAT ARE NOT PART OF THE RECORD IN THIS ACTION; EXPERT DISCOVERY DEADLINE; AND EXTEND PAGE LIMIT FOR OPENING MEMORANDA OF POINTS AND AUTHORITIES IN SUPPORT OF ANY MOTION FOR SUMMARY JUDGMENT OR PARTIAL SUMMARY JUDGMENT filed by Plaintiffs Danny Kortchmar, Don Henley, Mike Campbell. (Attachments: # 1 Proposed Order)(Charlesworth, Jacqueline)

Don Henley et al v. Charles S Devore et al

Doc. 44

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MORRISON & FOERSTER LLP JACQUELINE C. CHARLESWORTH (pro hac vice) [e-mail] CRAIG B. WHITNEY (CA SBN 217673) [e-mail] 1290 Avenue of the Americas New York, New York 10104 Telephone: [phone] Facsimile: 212.468.7900 PAUL GOLDSTEIN (CA SBN 79613) [e-mail] 559 Nathan Abbott Way Stanford, California 94305-8610 Telephone: [phone] Facsimile: 650.327.0811 Attorneys for Plaintiffs ONE LLP CHRISTOPHER W. ARLEDGE (CA SBN 200767) [e-mail] PETER AFRASIABI (CA SBN 193336) [e-mail] JOHN TEHRANIAN (CA SBN 211616) [e-mail] 535 Anton Boulevard, Suite 850 Costa Mesa, California 92626 Telephone: [phone] Facsimile: 714.434.8756 Attorneys for Defendants UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA DON HENLEY, MIKE CAMPBELL and DANNY KORTCHMAR, Plaintiffs, v. CHARLES S. DEVORE and JUSTIN HART, Defendants. AND RELATED COUNTERCLAIMS Case No. SACV09-0481 JVS (RNBx) Hon. James V. Selna STIPULATION REGARDING EXPERT DISCOVERY DEADLINES AND EXTENSION OF PAGE LIMIT [Filed Concurrently With Proposed Order]

ny-910496
Dockets.Justia.com

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WHEREAS, on July 28, 2009, the parties submitted their Joint Report Pursuant to Fed. R. Civ. P. 26(f) ("Joint Report"), which provides, inter alia, that the parties are to make their opening expert witness disclosures by January 25, 2010 and rebuttal expert witness disclosures by February 22, 2010; WHEREAS, the Joint Report further provides that expert discovery will conclude by March 22, 2010; WHEREAS, on August 10, 2009, the Court held a scheduling conference approving the parties' proposed deadlines, as reflected in the August 10, 2009 Civil Minutes ("Civil Minutes"); WHEREAS, the Civil Minutes provide that rebuttal disclosures of experts shall occur no later than February 22, 2010; WHEREAS, the Civil Minutes provide that expert discovery shall end March 22, 2010; WHEREAS, due to the geographic locations and availability of the various expert witnesses and conflicting travel obligations of the parties' counsel, the parties seek to extend certain expert discovery deadlines without affecting any other deadlines established by the Court; WHEREAS, the Local Rule 11-6 of the Central District of California provides that no memorandum of points and authorities shall exceed 25 pages in length; WHEREAS, the parties believe it will be difficult to address all necessary issues if their opening memoranda of points and authorities in support of a motion for summary judgment or partial summary judgment are limited to 25 pages; and WHEREAS, the parties wish to modify the schedule for expert discovery and increase the number of pages permissible for opening memoranda of points and authorities in support of any motion for summary judgment or partial summary judgment;
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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the parties through their undersigned counsel of record, subject to the Court's confirmation, that: 1. Expert discovery shall proceed as follows: (a) The parties shall exchange any rebuttal expert witness

disclosures, if any, along with all nonpublic materials relied upon by rebuttal experts that are not part of the record in this action, no later than February 26, 2010; (b) 2. Expert discovery shall be concluded no later than April 2, 2010; The page limit for opening memoranda of points and authorities in

support of any motion for summary judgment or partial summary judgment shall be extended from 25 pages to 35 pages. 3. Dated: No other deadlines in this action will be altered by this stipulation. February 12, 2010 MORRISON & FOERSTER LLP Jacqueline C. Charlesworth Craig B. Whitney Paul Goldstein By: /s/ Jacqueline C. Charlesworth Jacqueline C. Charlesworth

Attorneys for Plaintiffs DON HENLEY, MIKE CAMPBELL and DANNY KORTCHMAR Dated: February 12, 2010 ONE LLP Christopher W. Arledge Peter Afrasiabi John Tehranian By: /s/ Christopher W. Arledge Christopher W. Arledge

Attorneys for Defendants CHARLES S. DEVORE and JUSTIN HART

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