Sarnecki, et al v. Ford Motor Company, et al

Filing 15

STIPULATION and ORDER AMENDING PRETRIAL SCHEDULING ORDER signed by Judge Morrison C. England, Jr. on 05/28/10 ORDERING that Discovery cutoff is now 12/20/10; Designation of Expert Witnesses cutoff is now 02/14/11 with any rebuttal due by 03/17/11; Dispositive Motion due date is now 04/22/11. (Benson, A.)

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GATES, O'DOHERTY, GONTER & GUY, LLP
15373 Innovation Drive, Suite 170 San Diego, California 92128 Telephone: [phone] Facsimile: [phone]
Attorney:

DOUGLAS D. GUY, ESQ. (SBN 118744) [e-mail] VINCENT J. AXELSON, ESQ. (SBN 159549) [e-mail]

Attorneys for Defendant DAMON MOTOR COACH and LA MESA RV CENTER, INC.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ) ) ) ) Plaintiffs, ) ) v. ) ) FORD MOTOR COMPANY, DAMON MOTOR ) COACH, LA MESA R.V. CENTER, ) INC., and DOES 1-10, inclusive ) ) ) Defendants. ) ) OSCAR G. SARNECKI and SHIRLEY S. SARNECKI, CASE NO. 08-CV-02880-MCE-KJN STIPULATION AND PROPOSED ORDER BY ALL PARTIES TO AMEND THE COURT'S PRETRIAL SCHEDULING ORDER AND TO CONTINUE DISCOVERY CUTOFF, EXPERT DISCLOSURES, AND DISPOSITIVE MOTION DATE Judge: Morrison C. England, Jr. October 28, 2008

Action Filed:

Plaintiffs OSCAR and SHIRLEY SARNECKI, by and through their counsel of record, Douglas D. Law, Esq. of Law and Kolakowski, LLP and Defendants DAMON MOTOR COACH and LA MESA R.V. CENTER, by and through their attorney of record, Vincent J. Axelson, Esq. of Gates, O'Doherty, Gonter & Guy, LLP and defendant FORD MOTOR COMPANY, by and through their counsel of record, Kevin J. Tully, of the Law Offices of Kevin J. Tully, do hereby stipulate to amend the Court's Scheduling Order as follows: 1. The current April 14, 2010 discovery cutoff date shall be
1

continued to December 20, 2010.

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STIPULATION BY ALL PARTIES TO AMEND THE COURT'S PRETRIAL SCHEDULING ORDER AND TO CONTINUE DISCOVERY CUTOFF, EXPERT DISCLOSURES, AND DISPOSITIVE MOTION DATE

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2.

The current expert disclosure date of June 14, 2010 shall

be continued to February 14, 2011. 3. 4. All rebuttal experts shall be disclosed by March 7, 2011. The current dispositive motion due date of August 13, 2010

shall be continued to April 22, 2011. 5. All parties believe that good cause exists to amend the

scheduling order accordingly: 6. On February 3, 2010, the Court vacated the February 14, The Order

2011 trial date and continued it until October 24, 2011.

continuing the trial date, however, did not continue the discovery cutoff, expert disclosure or dispositive motion hearing dates. parties have not completed discovery, in part due to the fact plaintiffs' counsel has been engaged in trial. Thus, in light of the The

trial continuance, the parties believe it appropriate to continue the discovery cutoff, the expert disclosure, and the dispositive motion hearing dates as well. 7. For these reasons, the parties agree to continue the

discovery cutoff, the expert disclosure date, and the dispositive motion hearing due date as set forth above.

Dated:

May __, 2010

GATES, O'DOHERTY, GONTER & GUY, LLP

By:____________/s/________________________ VINCENT J. AXELSON Attorneys for Defendant DAMON MOTOR COACH and LA MESA RV CENTER, INC.

2 STIPULATION BY ALL PARTIES TO AMEND THE COURT'S PRETRIAL SCHEDULING ORDER AND TO CONTINUE DISCOVERY CUTOFF, EXPERT DISCLOSURES, AND DISPOSITIVE MOTION DATE

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION BY ALL PARTIES TO AMEND THE COURT'S PRETRIAL SCHEDULING ORDER AND TO CONTINUE DISCOVERY CUTOFF, EXPERT DISCLOSURES, AND DISPOSITIVE MOTION DATE

Dated:

May __, 2010

LAW & KOLAKOWSKI, LLP

By:___________/s/_________________________ DOUGLAS D. LAW LEONARD M. KOLAKOWSKI Attorneys for Plaintiffs OSCAR G. SARNECKI and SHIRLEY SARNECKI

Dated:

May __, 2010

LAW OFFICES OF KEVIN J. TULLY

By:__________ _/s/________________________ KEVIN TULLY Attorneys for Defendant FORD MOTOR COMPANY IT IS SO ORDERED. Dated:_May 28, 2010 __________________________________ MORRISON C. ENGLAND, JR UNITED STATES DISTRICT JUDGE

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