Viola Coppola, et al v. Gregory Smith, et al

Filing 437

STIPULATION and ORDER Extending Close of Expert Discovery Deadline: The Parties hereby stipulate to extend the expert discovery cut-off date, currently scheduled for September 23, 2016, to October 5, 2016. All other deadlines shall remain the same. signed by Magistrate Judge Barbara A. McAuliffe on 8/9/2016. (Herman, H)

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GREBEN & ASSOCIATES
125 E. DE LA GUERRA ST., STE 203
SANTA BARBARA, CA 93101
TEL: [phone]
FAX: [phone]

Jan A. Greben, SBN 103464
[e-mail]
Christine M. Monroe, SBN 304573
[e-mail]
Attorneys for Plaintiffs GARY COPPOLA, an individual; GARY COPPOLA, as SUCCESSOR
TRUSTEE OF THE VIOLA M. COPPOLA IRREVOCABLE TRUST; and GARY COPPOLA,
as TRUSTEE OF THE ANTHONY M. COPPOLA TRUST

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - FRESNO DIVISION

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GARY COPPOLA, an individual, GARY
COPPOLA, as SUCCESSOR TRUSTEE OF
THE VIOLA M. COPPOLA IRREVOCABLE
TRUST; and GARY COPPOLA, as TRUSTEE
OF THE ANTHONY M. COPPOLA TRUST;

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Plaintiffs,

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STIPULATION AND [PROPOSED] ORDER
EXTENDING CLOSE OF EXPERT
DISCOVERY DEADLINE

v.

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Case No.: 1:11-CV-01257-AWI-BAM

PARAGON CLEANERS (formerly sued as
GREGORY SMITH, an individual); et al.

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Defendants.

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RELATED CROSS AND COUNTERCLAIMS

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This stipulation is made by and between Plaintiffs Gary Coppola, Gary Coppola as

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successor trustee of the Viola M. Coppola Irrevocable Trust, and Gary Coppola as trustee of the

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Anthony M. Coppola Trust; Defendant Richard Laster; Defendant Paragon Cleaners, Inc.;

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Defendants the Jane Higgins Nash Trust, Jane Nash as Executor of the Estate of Decatur

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Higgins AKA the Estate of Mabel Elaine Higgins, Nash Properties LLC, David H. Nash and

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Richard P. Nash as the successor trustees of the Jane Nash Trust, a trust created under the terms

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of the Last Will and Testament of Mabel Elaine Higgins, formerly known as the Mabel Elaine

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Higgins Testamentary Trust and commonly known as the Jane Higgins Nash Trust; as well as

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Defendant City of Visalia (collectively “Parties”).

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The Parties hereby stipulate to extend the expert discovery cut-off date, currently scheduled
for September 23, 2016, to October 5, 2016. All other deadlines shall remain the same.

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The Parties respectfully request that the Court grant this short extension of the close of expert

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discovery set forth in the Court’s Scheduling Order, and the stipulated orders on certain expert

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deadlines [Documents 320, 374, 398, and 423] to consolidate the deadlines in this case with those in

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the Mission Linen Case1. All but one of the remaining parties are counsel in both the Coppola and

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Mission Linen cases, which have similar factual and technical issues. Good cause exists because

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counsel in the Mission Linen case were required to meet and confer on deadlines because trial was

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recently re-set per the Court’s calendar and the parties have reached the same agreement and wish to

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combine the depositions of overlapping experts in the interest of conserving resources. No other

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deadlines will be affected or modified as a result of this stipulation.

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Dated: August 4, 2016

GREBEN & ASSOCIATES

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/s/ Jan A. Greben
Jan A. Greben
Christine M. Monroe
Attorneys for Plaintiffs and Counter Defendants
GARY COPPOLA, an individual; GARY
COPPOLA, as SUCCESSOR TRUSTEE OF
THE VIOLA M. COPPOLA IRREVOCABLE
TRUST; and GARY COPPOLA, as TRUSTEE
OF THE ANTHONY M. COPPOLA TRUST

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Dated: August 4, 2016

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(Authorized on 8/4/2016)

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GUALCO LAW

/s/ Lori J. Gualco
Lori J. Gualco
Attorney for Defendant RICHARD LASTER

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Mission Linen Supply v. City of Visalia, Case No. 1:15-cv-00672-AWI-EPG

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Dated: August 4, 2016

GUALCO LAW

(Authorized on 8/4/2016)

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/s/ Lori J. Gualco

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Lori J. Gualco
Attorney for Defendant PARAGON
CLEANERS, INC.

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Dated: August 4, 2016

WILLIAMS, BRODERSEN & PRITCHETT
LLP

(Authorized on 8/4/2016)

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/s/ Steven R. Williams
Steven R. Williams
Attorney for Defendants THE JANE HIGGINS
NASH TRUST; JANE NASH, as EXECUTOR
OF THE ESTATE OF DECATUR HIGGINS
AKA THE ESTATE OF MABEL ELAINE
HIGGINS; NASH PROPERTIES, LLC; and
DAVID H. NASH, and RICHARD P. NASH, as
the SUCCESSOR TRUSTEES OF THE JANE
NASH TRUST, a trust created under the terms of
the Last Will and Testament of Mabel Elaine
Higgins, formerly known as the Mabel Elaine
Higgins Testamentary Trust and commonly
known as the Jane Higgins Nash Trust

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Dated: August 8, 2016

HERR, PEDERSEN & BERGLUND LLP

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(Authorized on 8/8/2016)
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/s/ Leonard C. Herr

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Leonard C. Herr
Ron Statler
Attorneys for Defendant CITY OF VISALIA

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IT IS SO ORDERED.
Dated:

/s/ Barbara

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE

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August 9, 2016

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