Henley v. Pacific Gas & Electric Company et al

Filing 18

STIPULATION and ORDER Modifying Scheduling Order, signed by Judge Oliver W. Wanger on 5/6/2011. (Close of non-expert discovery is 8/5/2011, Expert disclosures due 8/12/2011, and Expert discovery cut-off 9/5/2011. All other deadlines and hearing dates remain unchanged.)(Gaumnitz, R)

STACY A. CAMPOS, SBN 154658
PACIFIC GAS AND ELECTRIC COMPANY LAW DEPARTMENT
P.O. Box 7442
San Francisco, CA 94120
KATE DYER, SBN 171891
NICOLE HOWELL NEUBERT, SBN 246078
CLARENCE & DYER LLP
899 Ellis Street
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendant
PACIFIC GAS AND ELECTRIC COMPANY
LINDSAY R. NICHOLAS, SBN 273063
Leonard Carder, LLP
1188 Franklin St., Suite 201
San Francisco, CA 94109
[phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Defendant
INTERNATIONAL BROTHERHOOD OF
ELECTRICAL WORKERS, LOCAL UNION 1245
TODD B. BARSOTTI, SBN 148862
Barsotti & Baker, LLP
6592 North First Street
Fresno, CA 93710
Phone: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff Gary Henley

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
GARY HENLEY,

Case No. 1:10-CV-01119-OWW-GSA
Plaintiff,

v.
PACIFIC GAS AND ELECTRIC COMPANY,
LOCAL UNION NUMBER 1245 OF
INTERNATIONAL BROTHERHOOD OF
ELECTRICAL WORKERS, and DOES 1-50,
inclusive,
Defendants.

STIPULATION AND ORDER MODIFYING
SCHEDULING ORDER
Trial Date: January 18, 2012
Time: 9:00 a.m.
Courtroom 3, 7th Floor
Honorable Oliver W. Wanger

1

Pursuant to Civil Local Rules 143 and 137(b), the parties hereby jointly and respectfully submit a
stipulation and proposed order requesting that the Court revise the Scheduling Conference Order such
that, while certain discovery dates are modified, the motions deadlines and hearing dates, as well as the
Pre-trial Conference and Jury Trial dates remain unchanged.
The parties seek a modification of these dates in order to accommodate a private mediation
session with Thomas Simonian, Esq at JAMS mediation on July 11, 2011. The current pre-trial dates,
and proposed modifications, are as follows:

Event

Current Date

Proposed Date

Close of non-expert discovery

June 1, 2011

August 5, 2011

Expert disclosures due

July 15, 2011

August 12, 2011

Expert discovery cut-off

August 29, 2011

September 5, 2011

Settlement conference

September 13, 2011

same

Dispositive pre-trial motions due

September 29, 2011

same

Dispositive pre-trial motions hearing

October 31, 2011

same

Joint pre-trial statement due

December 5, 2011

same

Pre-trial conference

December 5, 2011

same

Jury Trial

January 18, 2012

same

The parties believe that the modified schedule will allow the parties an opportunity to participate
in a meaningful mediation session while potentially avoiding unnecessary discovery costs.

Dated: May 5, 2011

Respectfully submitted,

CLARENCE & DYER LLP
/s/ Nicole Howell Neubert
KATE DYER

2

NICOLE HOWELL NEUBERT
Attorneys for Defendant
Pacific Gas and Electric Company
LEONARD CARDER LLP
/s/: Lindsay R. Nicholas_________
Lindsay R. Nicholas
Attorneys for Defendant
IBEW LOCAL 1245
BARSOTTI & BAKER LLP
/s/: Todd Barsotti_____________
TODD BARSOTTI
Attorneys for Plaintiff
Gary Henley

Good cause having been shown, the pre-trial dates in this matter are modified as set out above.

IT IS SO ORDERED.
Dated:

May 6, 2011

/s/ Oliver W. Wanger
UNITED STATES DISTRICT JUDGE

DEAC_Signature-END:

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