Arizaga v. John Bean Technologies Corporation et al

Filing 59

Stipulation Re: Changing Date of Pre-Trial Conference and Expert Disclosure Deadlines; Order, signed by Magistrate Judge Michael J. Seng on 2/22/2016. (Yu, L)

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Warren R. Paboojian, Calif. Bar No. 128462
Adam B. Stirrup, Calif. Bar No. 257683
BARADAT & PABOOJIAN, INC.
720 W. Alluvial Ave.
Fresno, CA 93711
Phone: [phone]
Fax: [phone]
Attorneys for: Plaintiff Steven Arizaga
Mark D. Sayre, Calif. Bar No. 111168
Henry Turner, Jr. (pro hac)
VALOREM LAW GROUP LLP
35 E. Wacker Dr., Ste. 3000
Chicago, IL 60601
Phone: [phone]
Fax: [phone]
Attorneys for: Defendant John Bean Technologies Corporation
Meena C. Nachiappan, Calif. Bar No. 196701
BRAGG & KULUVA
555 S. Flower Street, Suite 600
Los Angeles, CA 90071
Phone: [phone]
Fax: [phone]
Attorney for: Third Party Defendant Ventura Coastal, LLC
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION
STEVEN ARIZAGA,

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Plaintiff,
vs.
JOHN BEAN TECHNOLOGIES
CORPORATION, et al.,

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Defendants.
___________________________________
JOHN BEAN TECHNOLOGIES
CORPORATION,

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Third-Party Plaintiff,
vs.
VENTURA COASTAL, LLC,
Third-Party Defendants.

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No. 13-cv-01981-AWI-MJS
Magistrate Judge Michael J. Seng
STIPULATION RE: CHANGING
DATES OF PRE-TRIAL CONFERENCE
AND EXPERT DISCLOSURE
DEADLINES; ORDER

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Stipulation Re: Changing Dates of Pre-Trial Conference and Expert Disclosure Deadlines and
Proposed Order – No. 13-cv-01981-MJS

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Plaintiff Steven Arizaga, Defendant John Bean Technologies Corporation, and ThirdParty Defendant Ventura Coastal LLC agree and stipulate as follows:
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the Pre-Trial Conference in this case, currently scheduled for March 25, 2016, fell on Good
Friday. Lead trial counsel for Defendant John Bean Technologies Corporation is committed to
take part in Good Friday services at his local parish on March 25, 2016.
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25, 2016 to March 24, 2016 at 11:00 a.m., subject to the Court’s availability.
3.

deposition of Third-Party Defendant Ventura Coastal LLC to February 26, 2016. The expected
testimony of Ventura Coastal’s 30(b)(6) witness(es) will impact the parties’ expert disclosures.
The parties have thus agreed and stipulated to move the deadlines for expert disclosures as
follows:
a. Plaintiff Expert Disclosure Deadline: March 16, 2016
b. Defendant Expert Disclosure Deadline: April 1, 2016

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Due to conflicts with counsel’s and witness’ availability and to allow for the

parties to take part in a February 1, 2016 mediation, the parties agreed to move the 30(b)(6)

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In light of the conflict for trial counsel for Defendant John Bean Technologies

Corporation, the parties have agreed and stipulated to move the Pre-Trial Conference from March

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Counsel for Defendant John Bean Technologies Corporation did not realize that

c. Rebuttal Expert Disclosure Deadline: April 6, 2016
4.

The parties agree and stipulate that all other pre-trial and trial dates and deadlines

shall remain in place under the Court’s prior Orders.
5.

By agreement, this stipulation may be executed in counterparts and via

email/facsimile, which when assembled shall be deemed one original document.
[SIGNATURE PAGES TO FOLLOW ON NEXT PAGE]

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Stipulation Re: Changing Dates of Pre-Trial Conference and Expert Disclosure Deadlines and
Proposed Order – No. 13-cv-01981-MJS

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IT IS SO STIPULATED.

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Dated: February 12, 2016

BARADAT & PABOOJIAN, INC.

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/s/ Adam B. Stirrup (as authorized on February 12,
2016)
Warren R. Paboojian, Calif. Bar No. 128462
Adam B. Stirrup, Calif. Bar No. 257683
720 W. Alluvial Ave.
Fresno, CA 93711
Attorneys for: Plaintiff Steven Arizaga

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Dated: February 16, 2016

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/s/ Henry Turner, Jr. ______________
Mark D. Sayre, Calif. Bar No. 111168
Henry Turner, Jr. (pro hac)
35 E. Wacker Dr., Ste. 3000
Chicago, IL 60601
Tele: [phone]
Fax: [phone]
Attorneys for: Defendant John Bean Technologies
Corporation

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VALOREM LAW GROUP, LLP

Dated: February 16, 2016

BRAGG & KULUVA
/s/ Meena C. Nachiappan (as authorized on February
16, 2016)
Meena C. Nachiappan, Bar No. 196701
555 S. Flower Street, Suite 600
Los Angeles, CA 90071
Phone: [phone]
Fax: [phone]
Attorneys for: Third Party Defendant Ventura Coastal,
LLC

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Stipulation Re: Changing Dates of Pre-Trial Conference and Expert Disclosure Deadlines and
Proposed Order – No. 13-cv-01981-MJS

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ORDER

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Pursuant to the Parties collective STIPULATION RE: CHANGING DATES OF

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PRE-TRIAL CONFERENCE AND EXPERT DISCLOSURE DEADLINES in Case No.

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13-cv-01981-AWI-MJS and for good cause shown, the Stipulation is accepted, adopted

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and made the Order of the Court.
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IT IS SO ORDERED.
Dated:

February 22, 2016

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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PROOF OF SERVICE

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I am a citizen of the United States and a resident of the State of Illinois. I am employed

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in Cook County, State of Illinois, in the office of a member of the bar of this Court, at whose

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direction this service is made. I am over the age of 18, and not a party to the within action. My

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business address is 35 East Wacker Drive, Suite 3000, Chicago, Illinois 60601.

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On February 18, 2016, I served a true and correct copy of the following document(s)
described as:
1. STIPULATION RE: CHANGING DATES OF PRE-TRIAL CONFERENCE AND
EXPERT DISCLOSURE DEADLINES;

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2. PROPOSED ORDER; and

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3. PROOF OF SERVICE

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on the following parties:

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Warren R. Paboojian
Adam B. Stirrup
Baradat & Paboojian
720 W. Alluvial Ave.
Fresno, CA 93711
[e-mail]
[e-mail]
Attorneys for Plaintiff

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in the following manner:

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Meena C. Nachiappan
Bragg & Kuluva
555 S. Flower Street, Suite 600
Los Angeles, CA 90071
[e-mail]
Attorneys for Third-Party Defendant Ventura
Coastal, LLC

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To be served upon all counsel of record via the Court’s ECF system.

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I declare under penalty of perjury under the laws of the State of California that the

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foregoing is true and correct. Executed on February 18, 2016, at Chicago, Illinois.

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Molly Wade

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PROOF OF SERVICE