Higgings v. Brusco Tug And Barge, Inc. et al

Filing 37

STIPULATION and ORDER signed by Judge William B. Shubb on 7/22/10 ORDERING that the Depositions of Dr. Rinzler and Dr. Pantazis may be conducted after the discovery cutoff date and are to be completed no later than 8/30/2010. Rebuttal expert disclosure and exchange of reports by 9/15/10. Close of Expert Discovery on 100/15/2010. Pretrial Conference is SET for 10/18/2010 at 02:00 PM. (Mena-Sanchez, L)

Higgings v. Brusco Tug And Barge, Inc. et al

Doc. 37

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COX, WOOTTON, GRIFFIN, HANSEN & POULOS, LLP
190 THE EMBARCADERO SAN FRANCISCO, CA 94105 TEL: [phone] FAX: [phone]

COX, WOOTTON, GRIFFIN, HANSEN & POULOS, LLP Richard C. Wootton (SBN 088390) Jody M. Taliaferro (SBN 252453) 190 The Embarcadero San Francisco, CA 94105 Telephone No.: 415-438-4600 Facsimile No.: 415-438-4601 Attorneys for Defendants Brusco Tug and Barge and The Dutra Group

E-Filing UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
JOHN D. HIGGINS, JR., ) ) Plaintiff, ) ) v. ) ) BRUSCO TUG AND BARGE AND THE ) DUTRA GROUP, ) Defendants. ) ___________________________________ ) Case No.: 2:08-CV-02300-WBS-KJN JOINT STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER

WHEREAS the the Plaintiff moved for and was granted a 60-day trial continuance on May 20, 2010. WHEREAS the trial continuance Order set the discovery deadline including expert disclosures to July 30, 2010, the pretrial conference to September 7, 2010 and jury trial on November 9, 2010. WHEREAS the parties having been working diligently to prepare this matter for trial on November 9, 2010, are prepared to provide expert disclosure and reports by the July 30, 2010 deadline and are not seeking an extension of trial date, the parties request additional time as follows to fully investigate the plaintiff's claims for traumatic brain injury: 1. The Depositions of Dr. Rinzler and Dr. Pantazis may be conducted after the -1Case No. 2:08-CV-02300-WBS-KJM
STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER

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NAV.Higgins/2675

Dockets.Justia.com

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COX, WOOTTON, GRIFFIN, HANSEN & POULOS, LLP
190 THE EMBARCADERO SAN FRANCISCO, CA 94105 TEL: [phone] FAX: [phone]

discovery cutoff date and are to be completed no later than August 30, 2010; 2. Rebuttal expert disclosure and exchange of reports by September 15, 2010; 3. Close of expert discovery on October 15, 2010; and 4. Pre-trial Conference October 19, 2010 The parties further stipulate that in the event a further IME of the plaintiff is required, such motion may be heard on shortened notice of seven (7) days.

DATED: July 23, 2010 Attorneys for Defendants

COX, WOOTTON, GRIFFIN, HANSEN & POULOS, LLP Brusco Tug and Barge and The Dutra Group By ____________/S/__________________ Richard C. Wootton

DATED: July 23, 2010 Attorneys for Plaintiff

LAW OFFICES OF DANIEL RAY BACON John D. Higgins, Jr. By _____________/S/_________________ Daniel Ray Bacon ORDER

Pursuant to the stipulation of the Parties in this action, through the respective counsel for the parties, and good cause appearing, IT IS ORDERED 1. The Depositions of Dr. Rinzler and Dr. Pantazis may be conducted after the discovery cutoff date and are to be completed no later than August 30, 2010;

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NAV.Higgins/2675

-2STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER

Case No. 2:08-CV-02300-WBS-KJM

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COX, WOOTTON, GRIFFIN, HANSEN & POULOS, LLP
190 THE EMBARCADERO SAN FRANCISCO, CA 94105 TEL: [phone] FAX: [phone]

2. Rebuttal expert disclosure and exchange of reports by September 15, 2010; 3. Close of expert discovery on October 15, 2010; and 4. Pre-trial Conference October 18, 2010 at 2:00 p.m. DATED: July 22, 2010

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NAV.Higgins/2675

-3STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER

Case No. 2:08-CV-02300-WBS-KJM