Multifamily Captive Group, LLC., v. Assurance Risk Managers, Inc., et al.,

Filing 129

STIPULATION and ORDER 128 signed by Judge Frank C. Damrell, Jr on 7/10/2009 GRANTING the Expert Discovery deadline be EXTENDED to October 9, 2009. (Krueger, M)

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Avi N. Wagner (CA Bar No. 226688) THE WAGNER FIRM 1801 Avenue of the Stars, Suite 307 Los Angeles, California 90067 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Counsel for Plaintiffs UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

MULTIMFAMILY CAPTIVE GROUP, LLC, a ) Maryland Corporation; and SAMANTHA ) GUMENICK, an individual, ) ) Plaintiffs, ) ) v. ) ) ASSURANCE RISK MANAGERS, INC., a ) Colorado Corporation; LISA ISOM, an ) individual; and CALIFORNIA APARTMENT ) ASSOCIATION, a California Corporation, ) ) Defendants. ) )

Case No. 2:08-CV-00547 FCD DAD STIPULATION AND ORDER EXTENDING EXPERT DISCOVERY PERIOD

Plaintiffs Multifamily Captive Group, LLC and Samantha Gumenick (collectively "Plaintiffs"), and defendants California Apartment Association ("CAA"), Lisa Isom ("Isom") and Assurance Risk Managers, Inc. ("ARM") (collectively "Defendants") make the following stipulation in connection with the following facts: WHEREAS, on June 25, 2009 the Court denied Plaintiffs' motion for the exclusion of expert testimony by Defendants' (the "Order"), extending the period for designating primary experts to July 3, 2009 and rebuttal experts on July 15, 2009 and ordered expert discovery to be completed by August 17, 2009;

1 STIPULATION AND ORDER EXTENDING EXPERT DISCOVERY PERIOD

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WHEREAS Plaintiffs had designated an expert prior to the Order and Defendants' designated an expert on July 3, 2009; WHEREAS, Plaintiffs' counsel had previously planned to be away at his nuptial and honeymoon during the majority of August 2009 (when, prior to the Order, no deadlines were scheduled); WHERAS at the request of Plaintiff' counsel (as result of the aforementioned nuptials and honeymoon), the parties have conferred and agreed to extend the deadline for expert discovery; NOW THERERFORE, the parties agree that under the circumstances the period for expert discovery (including depositions) should be extended to and including October 9, 2009. Respectfully submitted, Dated: July __, 2009 THE WAGNER FIRM / s/ Avi N. Wagner Avi N. Wagner Counsel for Plaintiffs Dated: July __, 2009 PAHL & MCKAY LLP / s/ Servando Sandoval (with permission to Avi Wagner ) Servando Sandoval Counsel for CAA Dated: July __, 2009 MILLER & LAW P.C. By: / s/ Curtis Henry (with permission to Avi Wagner ) Curits Henry By: By:

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ORDER Good cause appearing therefor, expert discovery (including depositions) should be extended to and including October 9, 2009.

_______________________________________ FRANK C. DAMRELL, JR. UNITED STATES DISTRICT JUDGE

3 STIPULATION AND ORDER EXTENDING EXPERT DISCOVERY PERIOD

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CERTIFICATE OF SERVICE The undersigned certifies that the above instrument was filed electronically with the Clerk of the Court via the CM/ECF system which effects notification to all parties registered and designated for the CM/ECF system in this action. Dated: July __, 2009 /s/ Avi N. Wagner Avi N. Wagner

1 STIPULATION AND ORDER EXTENDING EXPERT DISCOVERY PERIOD