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

Filing 79

STIPULATION and ORDER re Extending Expert Witness Discovery Deadline for the Taking of of Agreed Upon Expert Witness Depositions 75 . The expert discovery deadline is extended to September 15, 2016, for the depositions of (1) Peter Wrobel; and (2) Karl Schulze. Order signed by Magistrate Judge Sheila K. Oberto on 8/17/2016. (Timken, A)

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1 DYLAN J. LIDDIARD (State Bar No. 203055) WILSON SONSINI GOODRICH & ROSATI 2 Professional Corporation 650 Page Mill Road 3 Palo Alto, CA 94304 Telephone: (650) 493-9300 4 Facsimile: (650) 565-5100 Email: dliddiard@wsgr.com 5 Attorneys for Plaintiff 6 CALVIN E. DAVIS (State Bar No. 101640) 7 8 9 GORDON & REES LLP 633 West Fifth Street, 52nd Floor Los Angeles, CA 90071 Telephone: (213) 576-5000 Facsimile: (213) 680-4470 Email: cdavis@gordonrees.com Attorneys for Defendants 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 FRESNO DIVISION 13 G.P.P., Inc., d/b/a GUARDIAN INNOVATIVE 14 SOLUTIONS, Plaintiff, 15 16 v. 17 GUARDIAN PROTECTION PRODUCTS, INC. and RPM WOOD FINISHES GROUP, INC., 18 Defendants. 19 20 ) ) ) ) ) ) ) ) ) ) ) CASE NO. 1:15-cv-00321 SKO JOINT STIPULATION RE: EXTENDING EXPERT WITNESS DISCOVERY DEADLINE FOR THE TAKING OF AGREED UPON EXPERT WITNESS DEPOSITIONS; AND ORDER Plaintiff G.P.P., Inc. d/b/a Guardian Innovative Solutions (“Plaintiff” or “GIS”) and 21 Defendant Guardian Protection Products, Inc. (“Defendant” or “Guardian”) (collectively referred 22 to as “the parties”) submit the following Joint Stipulation re: Extending the Expert Witness 23 Discovery Deadline for the Taking of Agreed Upon Expert Witness Depositions. The parties have 24 been diligently working to complete expert witness discovery within the August 15, 2016 deadline 25 set by the court in its August 25, 2015, Scheduling Order for expert discovery relating to claims 26 pre-existing the Court’s July 27, 2016, Order Granting Plaintiff’s Motion to Amend. However, 27 due to scheduling conflicts and a dispute regarding the timeliness of an expert report offered by 28 Guardian, the parties will be unable to complete the agreed upon depositions of expert witnesses 1 prior to the current discovery cut-off date. 2 Therefore, the parties have agreed and have stipulated pursuant to Federal Rule of Civil 3 Procedure 29 to extend the time in which to complete these depositions to September 15, 2016. 4 The following depositions are subject to this Stipulation: (1) Peter Wrobel; and (2) Karl Schulze. 5 The parties respectfully request that the Court so-order the stipulation. 6 IT IS SO STIPULATED AND AGREED TO BY ALL PARTIES: 7 Dated: August 15, 2016 WILSON SONSINI GOODRICH & ROSATI 8 By: /s/ Dylan J. Liddiard Dylan J. Liddiard Attorneys for Plaintiff, GPP, INC. d/b/a GUARDIAN INNOVATIVE SOLUTIONS 9 10 11 Dated: August 15, 2016 GORDON & REES LLP 12 By: /s/ Calvin E. Davis as authorized on 8/12/16 Calvin E. Davis Gary A. Collis Margaret M. Drugan Attorneys for Defendants, GUARDIAN PROTECTION PRODUCTS, INC. and RPM WOOD FINISHES GROUP, INC. 13 14 15 16 17 ORDER 18 Pursuant to the parties’ stipulation and good cause shown, the expert discovery deadline is 19 extended to September 15, 2016, for the depositions of (1) Peter Wrobel; and (2) Karl Schulze. 20 21 IT IS SO ORDERED. 22 23 Dated: August 17, 2016 /s/ Sheila K. Oberto UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 2 .

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