Save Mart Supermarkets v. Escobar

Filing 19

STIPULATION and ORDER Continuing Non-Expert and Expert Discovery Deadlines signed by Magistrate Judge Gary S. Austin on 4/20/2012. Non-Expert Discovery now due by 7/2/2012; Expert Disclosure due by 7/23/2012; Supplemental Expert Disclosure due by 8/10/2012; Expert Discovery due by 8/30/2012.(Bradley, A)

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Clarissa A. Kang, SBN 210660
[e-mail]
Michelle L. Schuller, SBN 255787
[e-mail]
TRUCKER  HUSS
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

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Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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Attorneys for Plaintiff
SAVE MART SUPERMARKETS
Roger A. Moore, Esq. SBN: 146375
Law Offices of Roger A. Moore
A Professional Corporation
2291 West March Lane, Ste. A-102
Stockton, California 95207
Telephone: [phone]
Facsimile: [phone]

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Attorney for Defendant
STEPHEN ESCOBAR

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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SAVE MART SUPERMARKETS,
Plaintiff,

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STIPULATION AND ORDER
CONTINUING NON-EXPERT AND
EXPERT DISCOVERY DEADLINES

vs.

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Case No.: 1:11-CV-01685-LJO-GSA

STEPHEN ESCOBAR,
Defendant.

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Plaintiff SAVE MART SUPERMARKETS and Defendant STEPHEN ESCOBAR hereby

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stipulate, by and through their respective counsel, to continue the dates by which the parties are

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required to complete non-expert and expert discovery. The current deadlines for completion of

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non-expert and expert discovery were set by the Court’s March 17, 2012 Scheduling Conference

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Order (Docket # 17).
STIPULATION AND ORDER CONTINUING NON-EXPERT AND EXPERT DISCOVERY DEADLINES;
Case No.: 1:11-CV-01685-LJO-GSA
#1247092

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The parties agree and respectfully request that the deadlines for non-expert and expert

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discovery be continued for thirty (30) days, as follows:
Event

Deadline Set by Scheduling
Conference Order

[Proposed] Continued Date

Non-Expert Discovery

5/31/12

7/2/12

Expert Disclosure

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6/21/12

7/23/12

Supplemental Expert

7/11/12

8/10/12

7/31/12

8/30/12

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Cutoff
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Disclosure
Expert Discovery Cutoff

Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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The parties respectfully make this request because the parties believe that an approximately

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30-day extension is mutually convenient for all counsel and parties and will give the parties

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additional time to continue settlement negotiations.

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The parties have made no other modifications to deadlines in the case.

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The parties’ current request for a continuance of the non-expert and expert discovery

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deadlines will not alter any other dates or deadlines set by Court order.
DATED: April 19, 2012

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LAW OFFICES OF ROGER A. MOORE

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By: /s/ Roger A. Moore
Roger A. Moore
Attorneys for Defendant
STEPHEN ESCOBAR

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DATED: April 19, 2012
TRUCKER  HUSS

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By: /s/ Clarissa A. Kang
Clarissa A. Kang
Attorneys for Plaintiff
SAVE MART SUPERMARKETS

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STIPULATION AND ORDER CONTINUING NON-EXPERT AND EXPERT DISCOVERY DEADLINES;
Case No.: 1:11-CV-01685-LJO-GSA
#1247092

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I attest that my firm has obtained Mr. Moore’s concurrence in the filing of this document.

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DATED: April 19, 2012

TRUCKER  HUSS

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By: /s/ Clarissa A. Kang
Clarissa A. Kang

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IT IS SO ORDERED.
Dated:

April 20, 2012

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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DEAC_Signature-END:

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6i0kij8d

Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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STIPULATION AND ORDER CONTINUING NON-EXPERT AND EXPERT DISCOVERY DEADLINES;
Case No.: 1:11-CV-01685-LJO-GSA
#1247092

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