Mission Linen Supply v. City of Visalia

Filing 18

Stipulation and Second joint request for extension of time regarding close of non expert discovery and expert discovery and Order, signed by Magistrate Judge Erica P. Grosjean on 4/12/2016. (Initial Expert Disclosure due by 7/6/2016; Rebuttal Expert Disclosure due by 8/16/2016; Expert Discovery due by 8/29/2016) (Rosales, O)

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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 SECOND 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, having met and
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conferred on the issue of moving the following discovery dates listed in numbers 1 through 4
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below, hereby stipulate and agree that good cause exists for a second extension of discovery
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dates in this case. The first extension of discovery dates was made on February 5, 2016 and an
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order was signed and filed on February 8, 2016. Although Plaintiff’s and Defendant’s counsel

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have worked diligently to complete discovery in a timely manner, the depositions of the below
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three deponents have not been conducted due to counsel’s and client’s (corporate and city
representatives) busy schedules and other commitments. Also, Defendant City of Visalia’s

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FRCP Rule 30(b)(6) witnesses are being coordinated for a joint deposition with the case entitled
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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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

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Coppola v. Paragon Cleaners, Inc., et al., Case No.1:11-CV-01257-AWI-BAM. The Plaintiff

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and Defendant agree that the extended discovery dates shall be as follows:

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1.

Date of Non-Expert Discovery Cutoff extended from April 15, 2016 to May 15,

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2016 only for the depositions of the following witnesses to be conducted:

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Defendant City of Visalia FRCP Rule 30(b)(6) witness(es), Plaintiff Mission

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Linen Supply FRCP Rule 30(b)(6) witness(es), and Donald Moore;

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2.

Date of Initial Expert Disclosure extended from June 2, 2016 to July 6, 2016;

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3.

Date of Rebuttal Expert Disclosure extended from June 16, 2016 to August 16,

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2016; and

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4.

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

Date of Expert Discovery Cutoff extended from July 29, 2016 to August 29, 2016.

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Dated: April 7, 2016

GUALCO LAW

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By: /s/ Lori J. Gualco
LORI J. GUALCO
Attorney for Plaintiff MISSION LINEN
SUPPLY

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Dated: April 7, 2016

HERR PEDERSEN & BERGLUND LLP

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By: /s/ Leonard C. Herr, as authorized on 4/7/16
Leonard C. Herr
Ron Statler
Attorneys for Defendant CITY OF VISALIA

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ORDER
Based on the above Joint Stipulation of Plaintiff Mission Linen Supply and Defendant
City of Visalia, the extended dates for discovery are as follows:

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1. Date of Non-Expert Discovery Cutoff extended from April 15, 2016 to May 15, 2016

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only for the depositions of the following witnesses to be conducted: Defendant City of

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA 95814

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

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Visalia FRCP Rule 30(b)(6) witness(es), Plaintiff Mission Linen Supply FRCP Rule

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30(b)(6) witness(es), and Donald Moore;

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2.

Date of Initial Expert Disclosure extended from June 2, 2016 to July 6, 2016;

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3.

Date of Rebuttal Expert Disclosure extended from June 16, 2016 to August 16,

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2016; and

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4.

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All other dates and orders outlined in the scheduling order issued on August 13, 2015

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(Doc. 11) remain in full force and effect, including the deadline for the filing of dispositive

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motions, the pretrial conference, and the trial.

Date of Expert Discovery Cutoff extended from July 29, 2016 to August 29, 2016.

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IT IS SO ORDERED.
Dated:

April 12, 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 SECOND JOINT REQUEST FOR EXTENSION OF TIME RE: CLOSE OF NON-EXPERT & EXPERT
DISCOVERY AND ORDER