County of Sacramento v. Turbomeca, S.A. et al

Filing 77

STIPULATION and ORDER 76 to extend Scheduling Order signed by Judge William B. Shubb on 3/6/2012. Scheduling dates are MODIFIED as follows: Expert Disclosure date - 4/25/2012; Rebuttal Expert Witness Disclosure - 5/25/2012; All Discovery to be completed by 6/25/2012; All Motions to Compel Discover noticed and on calendar for 7/25/2012, as well as Motions being filed by 7/25/2012. The Final Pretrial Conference and Jury Trial dates shall remain unchanged. (Marciel, M)

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CHARLETON S. PEARSE, SBN 122491
ADAM M. AMBROZY, SBN 258237
BENJAMIN D. ORAM, SBN 269453
LENAHAN, LEE, SLATER & PEARSE, LLP
1030 15TH Street, Suite 300
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
COUNTY OF SACRAMENTO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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COUNTY OF SACRAMENTO,

Case No. 2:07-CV-01398-WBS-KJN

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Plaintiff,
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v.
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TURBOMECA, S.A., a French
Corporation; LA SOCIÉTÉ ANONYME
TURBOMECA FRANCÉ, a French
Corporation, TURBOMECA USA, a
Texas Corporation, TURBOMECA
ENGINE CORPORATION, a Texas
Corporation,

STIPULATION AND [PROPOSED]
ORDER REGARDING EXTENSION OF
EXPERT WITNESS DISCLOSURE AND
DISCOVERY DATES

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Defendants.

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In order to facilitate mediation and informal disclosure of expert reports prior to
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mediation, Plaintiff COUNTY OF SACRAMENTO, (hereinafter referred to as “Plaintiff”), and

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Defendants, TURBOMECA, S.A. and TURBOMECA USA (hereinafter collectively referred to

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as “Defendants”) hereby stipulate and seek an order of the Court modifying the Court’s April 1,

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2011 scheduling order as follows:

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(1)

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Section IV:
Expert disclosure date: April 25, 2012

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Rebuttal expert witness disclosure: May 25, 2012
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-1STIPULATION AND [PROPOSED] ORDER.

All discovery to be completed: June 25, 2012
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All motions to compel discovery noticed and on calendar: June 25, 2012

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Section V:

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All motions filed: July 25, 2012

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(2)

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The following dates are to remain unchanged and as ordered by the Court in its April 1,
2011 scheduling order and are as follows:

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Section VI:

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Final Pretrial Conference: August 20, 2012
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Section VII:

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Jury Trial: October 16, 2012

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(3)

No other aspects of the April 1, 2011 scheduling order are modified, altered, or changed.
This Stipulation and Order may be executed in counter-part, and faxed and/or authorized

electronic signature shall be deemed the same as an original execution.

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DATED: March 5, 2012

LENAHAN, LEE, SLATER & PEARSE, LLP

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By:

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_______________
__/s/Charleton S. Pearse
CHARLETON S. PEARSE
ADAM M. AMBROZY
BENJAMIN D. ORAM
Attorneys for Plaintiff,
COUNTY OF SACRAMENTO

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DATED: March 5, 2012

PERKINS COIE, LLP

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By:

__/s/Brendan Murphy ________________________
BRENDAN MURPHY
Attorneys for Defendant,
TURBOMECA, S.A. and TURBOMECA USA 

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-2STIPULATION AND [PROPOSED] ORDER.

ORDER

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IT IS HEREBY ORDERED THAT:

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(1)

The scheduling order is modified as follows:

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Section IV of the 4/1/2011 scheduling order:

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Expert disclosure date: April 25, 2012

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Rebuttal expert witness disclosure: May 25, 2012

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All discovery to be completed: June 25, 2012

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All motions to compel discovery noticed and on calendar: June 25, 2012

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Section V of the 4/1/2011 scheduling order:
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All motions filed: July 25, 2012

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(2)

The following dates are to remain as ordered by the Court in its April 1, 2011 scheduling

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order and are as follows:

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Section VI of the 4/1/2011 scheduling order:

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Final Pretrial Conference: August 20, 2012

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Section VII of the 4/1/2011 scheduling order:

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Jury Trial: October 16, 2012

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(3)

No other aspects of the April 1, 2011 scheduling order are modified, altered, or changed.
Dated: March 6, 2012

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-3STIPULATION AND [PROPOSED] ORDER.