Castillo v. JC Penney Corporation, Inc et al

Filing 18

STIPULATION and ORDER For Continuance of Expert Disclosure and Discovery Dates signed by Judge Oliver W. Wanger on 9/16/2010. (Esteves, C)

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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 MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP 5 RIVER PARK PLACE EAST FRESNO, CA 93720-1501 Anthony N. DeMaria, # 177894 McCormick, Barstow, Sheppard, Wayte & Carruth LLP P.O. Box 28912 5 River Park Place East Fresno, CA 93720-1501 Telephone: (559) 433-1300 Facsimile: (559) 433-2300 Attorneys for Defendant JC PENNEY CORPORATION, INC, (Incorrectly sued herein as "JCPENNEY") (SPACE BELOW FOR FILING STAMP ONLY) UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION MELORY CASTILLO, Plaintiff, v. JCPENNEY, and DOES 1 to 20, Defendant. Case No. 1:09-CV-01899-OWW-JLT STIPULATION AND ORDER FOR CONTINUANCE OF EXPERT DISCLOSURE AND DISCOVERY DATES Plaintiff MELORY CASTILLO, by and through her attorney of record Craig Johnson of the Law Office of Craig E Johnson, and Defendant JC PENNEY CORPORATION, INC, (Incorrectly sued herein as "JCPENNEY"), by and through their counsel of record Anthony N. DeMaria of McCormick, Barstow, Sheppard, Wayte and Carruth LLP, agree and stipulate as follows, 1. WHEREAS, pursuant to the Court's March 11, 2010 Scheduling Conference Order, expert disclosures are presently due September 15, 2010, and discovery is scheduled to close November 15, 2010; 2. WHEREAS, the parties are continuing to actively engage in settlement negotiations and discussions in this matter, and intend to continue to engage in settlement negotiations and alternative dispute mechanisms in an attempt to resolve this matter without the assistance 03664/00312-1618872.v1 STIPULATION AND ORDER FOR CONTINUANCE OF EXPERT DISCLOSURE AND DISCOVERY DATES 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 MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP 5 RIVER PARK PLACE EAST FRESNO, CA 93720-1501 of the court; 3. WHEREAS, based on the foregoing, and in the interest of economy and fairness, good cause exists to continue the date for expert disclosures, and discovery, and all dates associated therewith, for thirty (30) days in order to allow the parties an opportunity to continue to engage in settlement discussions in an effort to resolve this matter short of trial; 4. IT IS THEREFORE STIPULATED AND AGREED by, between and among the parties, and their attorneys of record, that expert disclosures, currently due September 15, 2010, and discovery, currently scheduled to close November 15, 2010, and all dates associated therewith, be continued to for thirty (30) days. IT IS SO STIPULATED. Dated: September 15, 2010 THE BECKER LAW FIRM By: /s/ Craig Johnson Craig Johnson Attorneys for Plaintiff MELORY CASTILLO Dated: September 15, 2010 McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP By: /s/ Marisa Balch (for Anthony DeMaria) Anthony N. DeMaria Attorneys for Defendants MCSWAIN UNION ELEMENTARY SCHOOL DISTRICT; TERRIE ROHRER; C.W. SMITH, and MARTHA HERNANDEZ NO FURTHER CONTINUANCES 03664/00312-1618872.v1 2 STIPULATION AND ORDER FOR CONTINUANCE OF EXPERT DISCLOSURE AND DISCOVERY DATES 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 MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP 5 RIVER PARK PLACE EAST FRESNO, CA 93720-1501 IT IS SO ORDERED. Dated: DEAC_Signature-END: September 16, 2010 /s/ Oliver W. Wanger UNITED STATES DISTRICT JUDGE emm0d64h 03664/00312-1618872.v1 3 STIPULATION AND ORDER FOR CONTINUANCE OF EXPERT DISCLOSURE AND DISCOVERY DATES

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