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)

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: [phone]

4 Facsimile: [phone]
Email: [e-mail]

5 Attorneys for Plaintiff
6 CALVIN E. DAVIS (State Bar No. 101640)
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GORDON & REES LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendants

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

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v.

17 GUARDIAN PROTECTION PRODUCTS, INC.
and RPM WOOD FINISHES GROUP, INC.,
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Defendants.
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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.
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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.
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IT IS SO STIPULATED AND AGREED TO BY ALL PARTIES:

7 Dated: August 15, 2016

WILSON SONSINI GOODRICH & ROSATI

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By:

/s/ Dylan J. Liddiard
Dylan J. Liddiard
Attorneys for Plaintiff,
GPP, INC. d/b/a GUARDIAN
INNOVATIVE SOLUTIONS

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11 Dated: August 15, 2016

GORDON & REES LLP

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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.

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ORDER

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Pursuant to the parties’ stipulation and good cause shown, the expert discovery deadline is

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extended to September 15, 2016, for the depositions of (1) Peter Wrobel; and (2) Karl Schulze.
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21 IT IS SO ORDERED.
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Dated:

August 17, 2016

/s/

Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE

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