Serquina v. The Raymond Corporation

Filing 20

STIPULATION and ORDER to Amend Scheduling Conference Order, to Continue Trial Date signed by Magistrate Judge Gary S. Austin on 3/30/2010. Non-expert disclosures deadline extended to 6/4/2010; Plaintiffs expert disclosure deadline extended to 6/1 1/2010; Defendants expert disclosure deadline extended to 6/25/2010; Supplemental expert disclosure deadline extended to 7/16/2010; Expert discovery extended to 8/20/2010; Non-dispositive motion deadline extended to 9/10/2010; Dispositive motion dead line extended to 10/1/2010; Settlement Conference set for 8/24/2010 at 10:30 AM in Courtroom 10 (GSA) before Magistrate Judge Gary S. Austin; Pretrial Conference set for 12/30/2010 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii; Jury Trial set for 3/1/2011 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii. (Esteves, C)

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MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
P.O. BOX 28912 FRESNO, CA 93729-8912

Michael F. Ball, # 116328 McCormick, Barstow, Sheppard, Wayte & Carruth LLP P.O. Box 28912 5 River Park Place East Fresno, CA 93720-1501 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant THE RAYMOND CORPORATION

(SPACE BELOW FOR FILING STAMP ONLY)

UNITED STATES DISTRICT COURT EASTERN DISTRICT URBANO SERQUINA Plaintiffs, v. THE RAYMOND CORPORATION, and DOES 1 through 20, Defendants. Case No. 1:08-CV-01741 AWI CSA STIPULATION TO AMEND SCHEDULING CONFERENCE ORDER, TO CONTINUE TRIAL DATE, AND ORDER THEREON Proposed New Dates: Discovery Deadlines: Non-Expert Disclosures: June 4, 2010 Expert Disclosures: Plaintiff: June 11, 2010 Defendant: June 25, 2010 Supp. Expert Disclosures: July 16, 2010 Expert Discovery: August 20, 2010 Motion Deadlines: Non Dispositive: September 10, 2010 Dispositive: October 1, 2010 Settlement Conference: August 24, 2010 10:30 a.m., Judge Gary S. Austin Pre-Trial Conference: September 30, 2010 8:30 a.m., Judge Anthony W. Ishii Trial (Jury: 10 days): November 30, 2010 8:30 a.m., Judge Anthony W. Ishii

1:08-CV-01741 AWI CSA STIPULATION TO AMEND SCHEDULING CONFERENCE ORDER

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MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
P.O. BOX 28912 FRESNO, CA 93729-8912

STIPULATION WHEREAS, Plaintiff URBANO SERQUINA and Defendant THE RAYMOND CORPORATION previously submitted a Mandatory Joint Scheduling Conference Report to the Court, and the Court, by Scheduling Conference Order issued January 20, 2009 established a schedule and trial date for the case; WHEREAS, Plaintiff and Defendant have not completed expert disclosures and expert discovery in the case; WHEREAS, Plaintiff and Defendant have agreed to extend the schedule set forth in the January 20, 2009 Scheduling Conference Order and continue the trial date as set forth in the (Proposed) Scheduling Order below. NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff and Defendant, through their respective counsel of record, and they each request that the Court enter an order amending the January 20, 2009 Scheduling Conference Order to adjust the schedule in the case as follows: 1. 2. 3. 4. The non-expert disclosures deadline shall be extended to June 4, 2010. Plaintiff's expert disclosure deadline shall be extended to June 11, 2010. Defendant's expert disclosure deadline shall be extended to June 25, 2010. The supplemental expert disclosure deadline shall be extended to July 16, 2010. 5. 6. The deadline for expert discovery shall be extended to August 20, 2010. The non-dispositive motion deadline shall be extended to September 10, 2010. 7. 8. The dispositive motion deadline shall be extended to October 1, 2010. A Settlement Conference shall be held in this case at 10:30 a.m. on August 24, 2010 before the Honorable Gary S. Austin, Magistrate Judge. 9. A Pre-Trial Conference shall be held in this case at 8:30 a.m. on September 30, 2010 before the honorable Anthony W. Ishii, Judge. /// 2
1:08-CV-01741 AWI CSA STIPULATION TO AMEND SCHEDULING CONFERENCE ORDER

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MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
P.O. BOX 28912 FRESNO, CA 93729-8912

10.

The Trial of this matter shall commence at 8:30 a.m. on November 30, 2010 before the honorable Anthony W. Ishii, Judge.

Dated: March 16, 2010

LAW OFFICES OF EDWARD B. CHATOIAN

By: /s/ Edward B. Chatoian (as authorized on March 16, 2010) Edward B. Chatoian Attorney for Plaintiff URBANO SERQUINA Dated: March 25, 2010 McCORMICK, BARSTOW, SHEPPARD WAYTE & CARRUTH LLP

By:

/s/ Michael F. Ball Michael F. Ball Attorneys for Defendant THE RAYMOND CORPORATION

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1:08-CV-01741 AWI CSA STIPULATION TO AMEND SCHEDULING CONFERENCE ORDER

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MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
P.O. BOX 28912 FRESNO, CA 93729-8912

ORDER The parties having so stipulated and agreed and good cause appearing, stipulation is ADOPTED IN PART. AMENDED as follows: 1. 2. 3. 4. The non-expert disclosures deadline shall be extended to June 4, 2010. Plaintiff's expert disclosure deadline shall be extended to June 11, 2010. Defendant's expert disclosure deadline shall be extended to June 25, 2010. The supplemental expert disclosure deadline shall be extended to July 16, 2010. 5. 6. The deadline for expert discovery shall be extended to August 20, 2010. The non-dispositive motion deadline shall be extended to September 10, 2010. 7. 8. The dispositive motion deadline shall be extended to October 1, 2010. A Settlement Conference shall be held in this case at 10:30 a.m. on August 24, 2010 before the Honorable Gary S. Austin, Magistrate Judge. 9. A Pre-Trial Conference shall be held in this case at 8:30 a.m. on December The January 20, 2009 Scheduling Conference Order is hereby

30, 2010 before the Honorable Anthony W. Ishii, Judge. 10. The Trial of this matter shall commence at 8:30 a.m. on March 1, 2011

before the Honorable Anthony W. Ishii, Judge. IT IS SO ORDERED. Date: March 30, 2010 /s/ Gary S. Austin ___________ Gary S. Austin United States Magistrate Judge

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1:08-CV-01741 AWI CSA STIPULATION TO AMEND SCHEDULING CONFERENCE ORDER