Moore v. Costco Wholesale Corporation

Filing 19

Joint STIPULATION to Extend Dates Set by Scheduling Order and ORDER signed by Magistrate Judge Gary S. Austin on 4/8/2011. Non-Expert Discovery due by 7/29/2011; Expert Disclosure due by 8/8/2011; Supplemental Expert Disclosure due by 8/29/2011; Expert Discovery due by 9/30/2011; Non-Dispositive Motions filed by 11/18/2011; Dispositive Motions filed by 1/13/2012; Pretrial Conference set for 4/12/2012 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii; Court Trial set for 6/5/2012 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii. (Bradley, A)

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K. Randolph Moore (SBN 106933)
Tanya E. Moore (SBN 206683)
MOORE LAW FIRM, P.C.
332 North Second Street
San Jose, California 95112
Telephone: [phone]
Facsimile: 408-298-6046

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Attorneys for Plaintiff Ronald Moore

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CHARLES A. VALENTE (State Bar # 242740)
KRASNOW SAUNDERS CORNBLATH, LLP
500 North Dearborn Street, 2nd Floor
Chicago, Illinois 60654
[phone]; Fax: [phone]

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Attorneys for Defendant Costco Wholesale Corporation

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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RONALD MOORE

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Plaintiff,
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vs.
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COSTCO WHOLESALE CORPORATION
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d/b/a COSTCO WHOLESLAE
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Defendant.
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_______________________________________)

Case No.: 10-cv-00929-AWI-GSA

JOINT STIPULATION TO EXTEND DATES
SET BY SCHEDULING ORDER; ORDER

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Plaintiff Ronald Moore, by his undersigned counsel, and Defendant Costco Wholesale

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Corporation, by its undersigned counsel, jointly stipulate to extend the schedule for various pre-trial

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dates as follows:

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WHEREAS, on November 29, 2011, this Court entered a Scheduling Order setting a schedule

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for this litigation;

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STIPULATION TO EXTEND DATES; ORDER

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WHEREAS, during the month of February 2011, one of the attorneys with primary

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responsibility for handling this matter was unexpectedly hospitalized and put through a battery of

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medical tests;

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WHEREAS, the attorney has been diagnosed with a serious disease which will require extensive

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surgery and several months of treatment. (The parties have been non-specific here to avoid putting

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personal medical information in the public record. If the Court so desires the specifics can be provided

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for in camera review.);

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NOW, THEREFORE, IT IS HEREBY AGREED AND STIPULATED AS FOLLOWS:

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1.

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In light of the situation, the parties have agreed to stay all discovery until June 24, 2011

and to continue all dates for 90 days as follows:

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Current Date

Proposed Date

April 29, 2011

July 29, 2011

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Complete Fact Discovery

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Disclose Experts

May 6, 2011

August 8, 2011

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Disclose Supplemental Experts

May 27, 2011

August 29, 2011

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Complete Expert Discovery

June 30, 2011

September 30, 2011

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Non-Dispositive Motions Filed By

August 19, 2011

November 18, 2011

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Dispositive Motions Filed by

October 14, 2011

January 13, 2012

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Pre-trial Conference Date

January 6, 2012

April 2012

February 28, 2012

June 2012

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Trial Date

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5, 2011.

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Responses to Plaintiff’s pending discovery under Rules 33, 34, and 36 will be due on July

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STIPULATION TO EXTEND DATES; ORDER

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Plaintiff’s Inspection of Costco’s premises will be continued to June 24, 2011 at 8:30

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a.m.

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Dated: March 29, 2011

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COSTCO WHOLESALE CORPORATION,
Defendant

By:

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ATTORNEYS FOR RONALD MOORE,
Plaintiff

By:

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/s/ Tanya E. Moore
One of His Attorneys
TANYA E. MOORE (SBN 206683)
K. RANDOLPH MOORE (SBN 106933)
MOORE LAW FIRM
332 N. Second Street
San Jose, CA 95112

/s/Charles Valente
One of Its Attorneys
CHARLES A. VALENTE (State Bar # 242740)
KRASNOW SAUNDERS CORNBLATH, LLP
500 North Dearborn Street,2nd Floor
Chicago, Illinois 60654

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ORDER

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The Parties having so stipulated, and good cause appearing, it is hereby ordered as follows:

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1.

Discovery in the matter shall be stayed through June 23, 2011;

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2.

The dates set in the Court’s Scheduling Order filed November 29, 2010 shall be

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continued as follows:

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Complete Fact Discovery

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Disclose Experts

August 8, 2011

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Disclose Supplemental Experts

August 29, 2011

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Complete Expert Discovery

September 30, 2011

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Non-Dispositive Motions Filed By

November 18, 2011

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Dispositive Motions Filed by

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Pre-trial Conference Date

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Trial Date

July 29, 2011

January 13, 2012
April 12, 2012
June 5, 2012

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STIPULATION TO EXTEND DATES; ORDER

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3. Responses to Plaintiff’s pending discovery under Rules 33, 34, and 36 are due July 5, 2011.

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4. Plaintiff’s Inspection of Costco’s premises will be continued to June 24, 2011 at 8:30 a.m.

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IT IS SO ORDERED.

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IT IS SO ORDERED.
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Dated:

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April 8, 2011

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

DEAC_Signature-END:

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STIPULATION TO EXTEND DATES; ORDER