G.P.P., Inc. v. Guardian Protection Products, Inc.

Filing 404

STIPULATION and ORDER REGARDING EXPERT DISCOVERY, signed by Magistrate Judge Sheila K. Oberto on 1/20/2021. (Kusamura, W)

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CALVIN E. DAVIS (SBN 101640)
[e-mail]
AARON P. RUDIN (SBN 223004)
[e-mail]
EMERSON H. KIM (SBN 285142)
[e-mail]
GORDON & REES LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants,
GUARDIAN PROTECTION PRODUCTS, INC. and
RPM WOOD FINISHES GROUP, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

Gordon & Rees LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071

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G.P.P., Inc., d/b/a GUARDIAN INNOVATIVE
SOLUTIONS

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Plaintiff,
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vs.
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GUARDIAN PROTECTION PRODUCTS, INC. and )
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RPM WOOD FINISHES GROUP, INC.
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Defendants.
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AND RELATED COUNTERCLAIM
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CASE NO. 1:15-cv-00321 SKO
STIPULATION AND ORDER
REGARDING EXPERT
DISCOVERY
(Doc. 403)

Pursuant to L.R.143, Defendant Guardian Protection Products, Inc. (“Guardian”) and
Plaintiff G.P.P., Inc., d/b/a Guardian Innovative Solutions (“GIS”) hereby stipulated as follows:
WHEREAS, on May 26, 2020, this Court issued an Order Granting Plaintiff’s Motion for
Leave to Supplement the Complaint (the “Order”).

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WHEREAS, the Order, among other things, reopened discovery for the limited purpose

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of addressing the issues of damages that have occurred since the trial in this case and as a result

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of the additional alleged breaches, and permitted each side one Rule 30(b)(6) deposition of no

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more than seven (7) hours, and any limited necessary written discovery related to the

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depositions.
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STIPULATION AND ORDER REGARDING EXPERT DISCOVERY

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WHEREAS, the Order did not expressly provide for expert discovery or further expert
depositions.
WHEREAS, Guardian and GIS believe that there is good cause for the Court to permit
additional expert discovery, including further expert depositions in this matter.

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WHEREAS, on January 5, 2021, GIS served a Supplemental Expert Witness Disclosure.

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WHEREFORE, Guardian and GIS hereby stipulate that:

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1.

Guardian shall provide its expert report to GIS by no later than February 5, 2021.

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2.

Guardian and GIS shall produce any documents relied upon in their expert reports

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Gordon & Rees LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071

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by no later than February 5, 2021, to the extent such documents have not already been produced
to the other side during discovery and/or during the prior trial in this matter.
3.

Guardian and GIS shall submit any rebuttal reports by no later than March 5,

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2021, along with any documents relied upon in the rebuttal reports, to the extent such documents

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have not already been produced.

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4.

Guardian and GIS shall be entitled to one deposition of each expert disclosed by

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the other side, not to exceed seven (7) hours, to be completed by no later than April 2, 2021.

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IT IS SO STIPULATED.

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Dated: January 19, 2021

GORDON & REES LLP

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By: /s/ Calvin E. Davis
Calvin E. Davis
Attorneys for Defendants

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Dated: January 19, 2021

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WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
By: /s/ Dylan J. Liddiard (as authorized on 1/19/21)
Dylan J. Liddiard
Attorneys for Plaintiff

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ORDER

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Based on the parties’ above-stipulation (Doc. 403), and for good cause shown, it is

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ORDERED that:

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1.

Guardian shall provide its expert report to GIS by no later than February 5, 2021;
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STIPULATION AND ORDER REGARDING EXPERT DISCOVERY

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2.

Guardian and GIS shall produce any documents relied upon in their expert reports

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by no later than February 5, 2021, to the extent such documents have not already

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been produced to the other side during discovery and/or during the prior trial in

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this matter;

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3.

Guardian and GIS shall submit any rebuttal reports by no later than March 5,

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2021, along with any documents relied upon in the rebuttal reports, to the extent

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such documents have not already been produced; and

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4.

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Guardian and GIS shall be entitled to one deposition of each expert disclosed by
the other side, not to exceed seven (7) hours, to be completed by no later than

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April 2, 2021.

Gordon & Rees LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071

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IT IS SO ORDERED.
Dated:

January 20, 2021

/s/

Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER REGARDING EXPERT DISCOVERY

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