Patterson v. Morgan Stanley Smith Barney, LLC

Filing 20

Joint STIPULATION and ORDER Regarding Deadlines for Expert Disclosures: (1) last day for disclosure of experts and expert reports by 12/1/2011; (2) lst day for disclosure of supplemental experts and supplemental reports by 12/15/2011; (3) close of discovery of expert witnesses by 1/1/2012. signed by Magistrate Judge Sandra M. Snyder on 8/24/2011. (Herman, H)

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TRISH M. HIGGINS (STATE BAR NO. 119215)
[e-mail]
ORRICK, HERRINGTON & SUTCLIFFE LLP
400 Capitol Mall, Suite 3000
Sacramento, CA 95814-4497
Telephone:
[phone]
Facsimile:
[phone]
SITTHIKIT CHARIYASATIT (STATE BAR NO. 252028)
[e-mail]
ORRICK, HERRINGTON & SUTCLIFFE LLP
1000 Marsh Road
Menlo Park, CA 94025
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
MORGAN STANLEY SMITH BARNEY LLC

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PETER SEAN BRADLEY, ESQ. (STATE BAR NO. 109258)
PENNER, BRADLEY & SIMONIAN
1171 West Shaw Avenue, Suite 102
Fresno, CA 93711
Telephone:
[phone]
Facsimile:
[phone]

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Attorney for Plaintiff
CLARENCE REITH PATTERSON, JR.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION

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CLARENCE REITH PATTERSON, JR.,

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Plaintiff,
v.

Case No. 1:10-cv-02084-LJO-SMS
JOINT STIPULATION AND ORDER
REGARDING DEADLINES FOR
EXPERT DISCLOSURES

Morgan Stanley Smith Barney, LLC
and Does 1 through 10, inclusive,

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Defendants.
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JOINT STIPULATION AND [PROPOSED] ORDER RE:
DEADLINES FOR EXPERT DISCLOSURES
1:10-CV-02084-LJO-GSA

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Plaintiff Clarence Reith Patterson, Jr. and Defendant Morgan Stanley Smith Barney, LLC
(collectively “the Parties”) stipulate as follows:

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WHEREAS, the Scheduling Conference Order dated February 16, 2011 set the deadline
for the disclosure of expert witnesses pursuant to Federal Rule of Civil Procedure 26(a)(2), (A)
and (B), for September 1, 2011;

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WHEREAS, the trial is not set to start until May 29, 2012;

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WHEREAS, the Parties agree, considering the schedules of the Parties, including trial
schedules, that there is insufficient time for the Parties to complete expert reports or expert
discovery before the discovery cutoff;

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WHEREAS, the Parties have not sought any previous scheduling changes in this matter;

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WHEREAS, the Parties’ stipulation would not affect the Dispositive Motion Filing
Deadline, the Settlement Conference Date, Pre-Trial Conference Date, or the Trial Date
scheduled for May 29, 2012 set by the Court;

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IT IS HEREBY STIPULATED by and between the parties to this action through their
designated counsel as follows:

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1.

from September 1, 2011 to December 1, 2011;

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the last day for disclosure of experts and expert reports shall be continued

2.

the last day for disclosure of supplemental experts and supplemental

reports shall be continued from September 15, 2011 to December 15, 2011; and
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3.

the close of discovery of expert witnesses shall be continued from

November 1, 2011 to January 1, 2012.

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Dated: August 22, 2011
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TRISH M. HIGGINS
SITTHIKIT CHARIYASATIT
ORRICK, HERRINGTON & SUTCLIFFE LLP

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/s/ Sitthikit Chariyasatit
SITTHIKIT CHARIYASATIT
Attorneys for Defendant
MORGAN STANLEY SMITH BARNEY LLC

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Dated: August 22, 2011

PETER SEAN BRADLEY
PENNER, BRADLEY & SIMONIAN

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/s/ Peter Sean Bradley
PETER SEAN BRADLEY
Attorney for Plaintiff
CLARENCE REITH PATTERSON, JR.

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ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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IT IS SO ORDERED.
Dated:

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August 24, 2011

/s/ Sandra M. Snyder
UNITED STATES MAGISTRATE JUDGE

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DEAC_Signature-END:

icido34h

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