Arnold v. Marriott International, Inc. et al

Filing 22

JOINT STIPULATION Regarding Continuance of Rebuttal Expert Disclosure and Discovery Deadlines; ORDER - Expert Disclosures - Rebuttals by 1/5/2011. Discovery Expert and Non-Expert Cut-off by 2/4/2011. signed by Magistrate Judge Sandra M. Snyder on 12/16/2011. (Herman, H)

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PATRICIA BARBOSA, Esq. (SBN 125865) JORDON METZ, Esq. (SBN 167355) BARBOSA, METZ & HARRISON, LLP 17547 Ventura Blvd., Suite 310 Encino, CA 91316 Tel: [phone] Fax: [phone] [e-mail] [e-mail] Attorneys for Plaintiff, CONNIE ARNOLD KATHLEEN E. FINNERTY (SBN 157638) GREENBURG & TRAURIG, LLP 1201 K Street, Suite 1100 Sacramento, CA 95814-3938 Tel: [phone] Fax: [phone] [e-mail] Attorneys for Defendant, W2005/FARGO HOTELS (POOL C) REALTY, L.P. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA CONNIE ARNOLD, Plaintiff, v. MARRIOTT INTERNATIONAL, INC. dba FAIRFIELD INN MARRIOTT-VISALIA; W2005/FARGO HOTELS (POOL C) REALTY, L.P. and DOES 1 through 35, Inclusive, Case No: 1:09-CV-01644-AWI-SMS Civil Rights JOINT STIPULATION REGARDING CONTINUANCE OF REBUTTAL EXPERT DISCLOSURE AND DISCOVERY DEADLINES; ORDER Trial Date: Time: Courtroom: June 28, 2011 8:30 a.m 2

Defendants. _________________________ Plaintiff CONNIE ARNOLD and Defendant W2005/FARGO HOTELS (POOL C) REALTY, L.P. hereby submit this Joint Stipulation and [Proposed] Order continuing the following discovery deadlines in the above-captioned case: The parties have recently reached an agreement in principle on the injunctive relief aspects of the case and are presently negotiating settlement of the damages and attorneys' fees in the case. Given this material progress toward settlement, the parties
JOINT STIPULATION REGARDING CONTINUANCE OF REBUTTAL EXPERT DISCLOSURE AND DISCOVERY DEADLINES (CASE NO. 1:09-cv-01644-AWI-

SMS)

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107858612_2.DOC

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FTL 107,858,612v3 12-14-10

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believe the prospect of settlement is greatly enhanced by saving time and money on discovery unless their settlement discussions fail. This, coupled with the nearing holidays, cause the parties to jointly request that the court extend the pre-trial deadlines in this case as follows: WHEREAS, this is a second continuance requested by the parties and this continuance does not alter the Trial date set in this matter. NOW, THEREFORE, IT IS HEREBY JOINTLY STIPULATED, subject to the Court's approval, that the dates previously set by this Court be continued as follows: Old Date December 15, 2010 Proposed Date January 5, 2011 Deadline Expert Disclosures ­ Rebuttals (FRCP 26(a)(2)) Expert and Non-Expert Discovery Cut-off

January 14, 2011

February 4, 2011

IT IS SO STIPULATED. Dated: December 14, 2010 BARBOSA, METZ, IKEDA & HARRISON, LLP ______/s/Jordon Metz_________ JORDON METZ Attorneys for Plaintiff, CONNIE ARNOLD Dated: December 14, 2010 GREENBURG & TRAURIG, LLP __/s/Kathleen E. Finnerty __ KATHLEEN E. FINNERTY Attorneys for Defendant W2005/FARGO HOTELS (POOL C) REALTY, L.P. IT IS SO ORDERED. Dated: December 16, 2011 /s/ Sandra M. Snyder SANDRA M. SNYDER United States District Court Magistrate Judge

JOINT STIPULATION REGARDING CONTINUANCE OF REBUTTAL EXPERT DISCLOSURE AND DISCOVERY DEADLINES (CASE NO. 1:09-cv-01644-AWI-

SMS)

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107858612_2.DOC

PDF created with pdfFactory trial version www.pdffactory.com

FTL 107,858,612v3 12-14-10