United States of America v. Timberline Environmental Services, et al.

Filing 12

STIPULATION and ORDER Regarding Case Schedule, signed by Judge Oliver W. Wanger on 1/15/2009. Non-Expert Discovery due by 5/22/2009. Expert Witness Disclosure due by 6/5/2009. Supplemental Expert Disclosure due by 6/26/2009. Expert Discovery due by 7/24/2009. Non-Dispositive Motions due by 8/14/2009. Dispositive Motion due by 8/25/2009. Settlement Conference set for 8/6/2009. Pretrial Conference set for 11/2/2009. Jury Trial set for 1/12/2010. (Sondheim, M)

1 2 3 4 5 6 7 8 9 10 11 12

LAWRENCE G. BROWN Acting United States Attorney STEPHANIE HAMILTON BORCHERS Assistant United States Attorney United States Courthouse, Suite 4401 2500 Tulare Street Fresno, CA 93721 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff United States of America

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) ) v. ) ) ) TIMBERLINE ENVIRONMENTAL ) SERVICES, TERRY NORTHCUTT AND ) JILL NORTHCUTT, ) ) Defendants. ) ______________________________ Case No.: 1:08-cv-0527 OWW GSA STIPULATION REGARDING CASE SCHEDULE ORDER

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Plaintiff United States of America ("United States") and Defendants Timberline Environmental Services, Terry Northcutt and Jill Northcutt (collectively "Defendants") respectfully submit this stipulation regarding the case schedule. The parties seek

to extend the discovery and other dates in this case due to the out-of-country work schedule of key witnesses which has made scheduling depositions difficult. Additionally, the parties

anticipate mediating once more discovery is completed. -1S T I P U L A T I O N REGARDING CASE SCHEDULE [PROPOSED ORDER]

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

Accordingly, the parties jointly request that the case schedule be continued as follows: Old Dates Expert Witness Disclosure: Supplemental Expert Disclosure: Non-Expert Discovery cut-off: Expert Discovery cut-off: Non-dispositive motion filing deadline: Dispositive motion filing deadline: Settlement Conference: Pretrial Conference: Trial: March 6, 2009 March 27, 2009 February 20, 2009 April 24, 2009 May 14, 2009 May 25, 2009 May 6, 2009 August 3, 2009 September 15, 2009 New Dates June 5, 2009 June 26, 2009 May 22, 2009 July 24, 2009 August 14, 2009 August 25, 2009 August 6, 2009 November 2, 2009 January 12, 2010

Respectfully submitted, Dated: January 14, 2009 LAWRENCE G. BROWN Acting United States Attorney /s/Stephanie Hamilton Borchers STEPHANIE HAMILTON BORCHERS Assistant U.S. Attorney Attorneys for Plaintiff UNITED STATES OF AMERICA Dated: January 13, 2009 LAW OFFICES OF NISSON, PINCIN & HILL

23 24 25 26 27 28 -2-

/s/ Duane H. Timmons DUANE H. TIMMONS Attorney for Defendants TIMBERLINE ENVIRONMENTAL SERVICES, TERRY NORTHCUTT AND JILL NORTHCUTT

S T I P U L A T I O N REGARDING CASE SCHEDULE [PROPOSED ORDER]

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

IT IS SO ORDERED. Dated: January 15, 2009 emm0d6 /s/ Oliver W. Wanger UNITED STATES DISTRICT JUDGE

-3S T I P U L A T I O N REGARDING CASE SCHEDULE [PROPOSED ORDER]