Mission Linen Supply v. City of Visalia

Filing 16

STIPULATION and ORDER GRANTING the parties' request for an extension of the following deadlines: Non-Expert Discovery deadline extended to 4/15/2016; Initial Expert Disclosure extended to 6/2/2016; Rebuttal Expert Witness Disclosure extended to 6/16/2016; and Discovery and Expert Discovery deadline is extended to 7/29/2016. All other dates and orders outlined in the Scheduling Order issued on 8/13/2015, document 11 , remain in full force and effect. Order signed by Magistrate Judge Erica P. Grosjean on 2/9/2016. (Rooney, M)

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LORI J. GUALCO (Bar No. 95232)
GUALCO LAW
400 Capitol Mall, Eleventh Floor
Sacramento, CA 95814
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff
MISSION LINEN SUPPLY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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MISSION LINEN SUPPLY,

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Case No. 1:15-cv-00672-AWI-EPG

Plaintiff,

STIPULATION AND JOINT REQUEST
FOR EXTENSION OF TIME
REGARDING CLOSE OF NONEXPERT DISCOVERY AND EXPERT
DISCOVERY AND ORDER

Defendant.

Date Complaint Filed: May 1, 2015
Trial Date: December 13, 2016

v.
CITY OF VISALIA,

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Plaintiff Mission Linen Supply (“Plaintiff”), by and through its attorney of record, Gualco
Law and Lori J. Gualco, and Defendant City of Visalia (“Defendant”), by and through its

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attorneys of record, Herr Pedersen & Berglund LLP and Leonard C. Herr have worked diligently
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to complete discovery in a timely manner, taking into account the schedules of witnesses and legal
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counsel; however, with the ambitious schedule to which both initially agreed, that schedule cannot
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be met given the full calendars of counsel, clients (corporate and city representatives) and
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percipient and expert environmental consultants.
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The parties have met and conferred on the issue of moving the following discovery dates
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listed in numbers 1 through 4 below, and hereby stipulate and agree that good cause exists for an
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extension of those discovery dates and agree that the extended discovery dates shall be as follows:
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1.

Date of Non-Expert Discovery Cutoff extended from March 16, 2016

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to April 15, 2016;
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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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STIPULATION AND JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT DISCOVERY
AND ORDER

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2.

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2016;
3.

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Date of Initial Expert Disclosure extended from May 2, 2016 to June 2,

Date of Rebuttal Expert Disclosure extended from May 16, 2016 to
June 16, 2016; and

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Date of Discovery Cutoff and Expert Discovery Cutoff extended from
June 30, 2016 to July 29, 2016.

The parties jointly move for an order regarding the above dates.

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Dated: February 8, 2016

GUALCO LAW

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By: /s/ Lori J. Gualco (as authorized on 2/8/2016)
LORI J. GUALCO
Attorney for Plaintiff MISSION LINEN
SUPPLY

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Dated: February 8, 2016

HERR PEDERSEN & BERGLUND LLP

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By: /s/ Leonard C. Herr___________________
LEONARD C. HERR
Attorneys for Defendant CITY OF VISALIA

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ORDER

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Based on the above Joint Stipulation of Plaintiff Mission Linen Supply and Defendant
City of Visalia (Doc. 15), the extended dates for discovery are as follows:
1. The Non-Expert Discovery Cutoff is extended from March 16, 2016 to April 15,
2016;

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2. The Initial Expert Disclosure is extended from May 2, 2016 to June 2, 2016;

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3. The Rebuttal Expert Disclosure is extended from May 16, 2016 to June 16, 2016; and

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4. The Discovery Cutoff and Expert Discovery Cutoff is extended from June 30, 2016 to

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July 29, 2016.

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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STIPULATION AND JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT DISCOVERY
AND ORDER

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All other dates and orders outlined in the scheduling order issued on August 13, 2015
(Doc. 11) remain in full force and effect.

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IT IS SO ORDERED.
Dated:

February 9, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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STIPULATION AND JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT DISCOVERY
AND ORDER