Mission Linen Supply v. City of Visalia

Filing 38

STIPULATION and ORDER GRANTING the parties' request modifying deadlines and hearings as follows: Defendant shall supplement expert disclosures based on the new documents received as discussed at the informal discovery dispute hearing no later th an 8/11/2016; Rebuttal expert discovery deadline is 8/30/2016; Expert discovery cutoff is extended to October 5, 2016; Dispositive motions shall be filed no later than 12/5/2016; Pre-trial conference will be held on 3/22/2017 at 10:00 AM before District Judge Anthony W. Ishii; and the Jury Trial is set for 5/23/2017 at 08:30 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii. Order signed by Magistrate Judge Erica P. Grosjean on 8/16/2016. (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]
JAN A. GREBEN (Bar No. 103464)
CHRISTINE M. MONROE (Bar No. 304573)
GREBEN & ASSOCIATES
125 E. De La Guerra Street, Suite 203
Santa Barbara, CA 93101
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys 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,

JOINT STIPULATION FOLLOWING
RESCHEDULING OF THE TRIAL
DATE REGARDING REBUTTAL
EXPERT DISCOVERY DEADLINE AND
ORDER

Defendant.

Date Complaint Filed: May 1, 2015
Trial Date: May 23, 2017 at 8:30 am

v.
CITY OF VISALIA,

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Plaintiff Mission Linen Supply (“Plaintiff Mission”), by and through its attorneys of

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record, Gualco Law and Lori J. Gualco, and Greben & Associates and Jan A. Greben, and
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Defendant City of Visalia (“Defendant City”), by and through its attorneys of record, Herr,

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Pedersen & Berglund LLP and Leonard C. Herr and Ron Statler, having met and conferred on the
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issue of returning the date for rebuttal expert discovery deadline to August 30, 2016, as set forth
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in the Court’s Order dated May 12, 2016 [Document 25], hereby stipulate and agree that good

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cause exists for the rebuttal expert discovery deadline to be August 30, 2016, and for the trial
GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA
95814

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JOINT STIPULATION FOLLOWING RESCHEDULING OF TRIAL DATE RE:
REBUTTAL EXPERT DISCOVERY DEADLINE AND ORDER

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date to be Tuesday, May 23, 2017, at 8:30 a.m., before District Judge Anthony W. Ishii. There

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have been several stipulations and requests for orders granting extension of discovery dates

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submitted to the Court in this case, and all have been granted [Documents 16, 18, 25, and 36].

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The trial date was rescheduled from December 13, 2016 to May 22, 2017, and the parties

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stipulated and agreed that the close of discovery regarding expert witnesses be extended from

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September 12, 2016 to October 5, 2016. The Court granted this request by Order dated August 9,

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2016 [Document 36]. In that Order, the Court changed the rebuttal expert discovery deadline

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from August 30, 2016, to August 26, 2016.

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Due to expert discovery being coordinated in this case and with the Coppola v. Paragon

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Cleaners, Inc., et al. case for several joint expert depositions, the parties request that the date for

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rebuttal expert discovery deadline be returned to August 30, 2016, as set forth in the Order dated

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May 12, 2016 [Document 25], so that it is consistent with the rebuttal expert discovery deadline

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date in the Coppola v. Paragon Cleaners, Inc., et al., Case No. 1:11-cv-01257-AWI-BAM

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[Document 423 dated June 20, 2016].

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Plaintiff Mission and Defendant City stipulate and agree that the dates shall be as
follows:
1.

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Date of rebuttal expert discovery deadline be changed from August 26, 2016, to
August 30, 2016.

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Trial date be confirmed for Tuesday, May 23, 2017, in conformance with Judge
Ishii’s standing order regarding trials commencing in his courtroom on Tuesday.

Plaintiff Mission and Defendant City jointly move for an order regarding the above dates.

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Dated: August 15, 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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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA
95814

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JOINT STIPULATION FOLLOWING RESCHEDULING OF TRIAL DATE RE:
REBUTTAL EXPERT DISCOVERY DEADLINE AND ORDER

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Dated: August 15, 2016

GREBEN & ASSOCIATES

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By: /s/ Jan A. Greben as authorized on 8-15-16
JAN A. GREBEN
Attorneys for Plaintiff MISSION LINEN
SUPPLY

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Dated: August 15, 2016

HERR PEDERSEN & BERGLUND LLP

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By: /s/ Leonard C. Herr as authorized on 8-15-16
LEONARD C. HERR
RON STATLER
Attorneys for Defendant CITY OF VISALIA

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ORDER

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The Court has reviewed the Stipulation submitted above, and the deadlines in this case
are as follows:

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1. Defendant shall supplement expert disclosures based on the new documents received as

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discussed at the informal discovery dispute hearing no later than August 11, 2016;

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2. The rebuttal expert discovery deadline is August 30, 2016;

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3. The expert discovery cutoff is extended from September 12, 2016 to October 5, 2016;

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4. Dispositive motions shall be filed no later than December 5, 2016;

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5. The pre-trial conference will be held on March 22, 2017, at 10:00 a.m. before Judge

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Ishii; and

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6. The trial will be held on Tuesday, May 23, 2017, at 8:30 a.m. before Judge Ishii.

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA
95814

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JOINT STIPULATION FOLLOWING RESCHEDULING OF TRIAL DATE RE:
REBUTTAL EXPERT DISCOVERY DEADLINE AND ORDER

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All other orders contained in this Court’s scheduling order issued on August 13, 2015
(Doc. 11) remain in full force and effect.

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IT IS SO ORDERED.
Dated:

August 16, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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GUALCO LAW
400 Capitol Mall
Eleventh Floor
Sacramento, CA
95814

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JOINT STIPULATION FOLLOWING RESCHEDULING OF TRIAL DATE RE:
REBUTTAL EXPERT DISCOVERY DEADLINE AND ORDER