Arnold v. La Quinta Corporation et al

Filing 38

STIPULATION and ORDER re extension of deadlines set forth in scheduling order. Discovery pertaining to experts continued from 10/1/2009 to 10/16/2009. Disclosure of expert witnesses continued from 8/3/2009 to 9/14/2009. Disclosure of all supplement al experts continued from 9/1/2009 to 9/28/2009. Filing of Non-Dispositive Motions continued from 9/16/2009 to 9/30/2009. Filing of Dispositive motions continued from 9/25/2009 to 10/23/2009. Order signed by Magistrate Judge Dennis L. Beck on 7/21/2009. (Hernandez, M)

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Gary R. Basham (SBN 130119) Meagan D. Christiansen (SBN 240679) BASHAM PARKER LLP 701 University Avenue, Suite 220 Sacramento, California 95825 Telephone: [phone] Facsimile: [phone] Attorney for Defendant IC KANG CORPORATION Theordore W. Hoppe (SBN 138064) HOPPE LAW GROUP Hoppe Law Group 680 W. Shaw Ave., Ste. 207 Fresno, CA 93704 Telephone: [phone] Facsimile: [phone] Attorney for Defendant LIBERTY HOTEL INV., L.P.

Jordon Metz (SBN 167355) Margaret Byrne Ikeda (SBN 222303) GOODMAN & METZ 17043 Ventura Blvd. Encino, CA 91316 Telephone: [phone] Facsimile: [phone] Patricia Barbosa (SBN 125865) BARBOSA GROUP 9341 Candlewood Drive Huntington Beach, CA 92646 Tel: [phone] Fax: [phone] Attorneys for Plaintiff CONNIE ARNOLD

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA CONNIE ARNOLD, Plaintiff, v. IC KANG CORPORATION, d.b.a. LA QUINTA INN & SUITES ­ VISALIA; OMKAR INNS, INC.; and DOES 1 through 35, inclusive, Defendants. Case No. 1:08-CV-01246-AWI-DLB STIPULATION AND ORDER RE EXTENSION OF DEADLINES SET FORTH IN SCHEDULING ORDER

Complaint Filed: August 22, 2008 Trial Date: February 23, 2010

TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS: Plaintiff CONNIE ARNOLD and Defendants IC KANG CORPORATION and LIBERTY HOTEL INVESTMENT, L.P., by and through their respective attorneys of record, hereby stipulate and agree to extend several deadlines originally set in the Scheduling Order as described below. The parties stipulate that good cause exists to extend the various pre-trial deadlines based upon the following considerations:
Stipulation And [Proposed] Order Re Extension Of Deadlines Set Forth In Scheduling Order

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Case No. 1:08-CV-01246-AWI-DLB

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1.

Plaintiff and Defendants are currently engaging in good faith discussions to

settle this matter and wish to avoid further litigation costs to all parties involved, in the hopes that this matter will soon be settled. 2. 3. There is currently a Settlement Conference set for September 1, 2009. Plaintiff and Defendants have looming deadlines which require extensive

filings either before or just after the Settlement Conference takes place. If the deadlines set forth in the Scheduling Order are not extended, all parties will be required to incur substantial fees and costs that may prove unnecessary. Therefore, the parties request additional time to avoid waste of judicial and/or party resources. 4. The extension of the various pre-trial deadlines will in no way affect the

trial date of February 23, 2010. IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff CONNIE ARNOLD and Defendants IC KANG CORPORATION and LIBERTY HOTEL INVESTMENT, L.P., through their respective attorneys of record: 1. To extend the deadline for parties to complete all discovery pertaining

experts from October 1, 2009 to October 16, 2009; 2. To extend the deadline for parties to disclose all expert witnesses, in

writing, from August 3, 2009 to September 14, 2009; 3. To extend the deadline for parties to disclose all supplemental experts,

from September 1, 2009 to September 28, 2009; 4. To extend the deadline for the filing of all Non-Dispositive Pre-Trial

Motions, including any discovery motions, from September 16, 2009 to September 30, 2009; 5. To extend the deadline for the hearing of all Non-Dispositive Pre-Trial

Motions, including any discovery motions, from October 9, 2009 to October 23, 2009; 6. To extend the deadline for the filing of all Dispositive Pre-Trial Motions,

including any discovery motions, from September 25, 2009 to October 23, 2009; and 7. To extend the deadline for the hearing of all Dispositive Pre-Trial Motions,

including any discovery motions, from October 26, 2009 to November 23, 2009. 2
Stipulation And [Proposed] Order Re Extension Of Deadlines Set Forth In Scheduling Order Case No. 1:08-CV-01246-AWI-DLB

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These extensions are agreed to between counsel for the parties with a good faith desire to continue in settlement discussions without the real possibility that the looming deadlines may cause the parties to incur such additional expense that settlement discussions may be hampered. Accordingly, all counsel respectfully request that the Court grant an order pursuant to the terms stipulated here. IT IS SO STIPULATED. Date: _7/15/09________, 2009 GOODMAN & METZ By: /S/MARGARET BYRNE IKEDA JORDON METZ MARGARET BYRNE IKEDA Attorney for Plaintiff CONNIE ARNOLD Date: _7/15/09________, 2009 HOPPE LAW GROUP By: /S/THEORDORE W. HOPPE THEORDORE W. HOPPE Attorney for Defendant LIBERTY HOTEL INV., L.P. Date: _July 15_______, 2009 BASHAM PARKER LLP By: /S/GARY BASHAM GARY BASHAM Attorney for Defendant IC KANG CORPORATION IT IS SO ORDERED: Dated: 21 July 2009 /S/ Dennis

L. Beck

UNITED STATES MAGISTRATE JUDGE 3
Case No. 1:08-CV-01246-AWI-DLB

Stipulation And [Proposed] Order Re Extension Of Deadlines Set Forth In Scheduling Order