Zamora v. Department of Homeland Security et al

Filing 52

ORDER signed by Judge John A. Mendez on 9/10/1 re 51 ORDERING that expert witness disclosures ddl is EXTENDED to 9/17/2010.(Duong, D)

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Mark E. Ellis - 127159 Ronald R. Poirier - 175511 Teresa Zuber - 164213 ELLIS, LaVOIE, POIRIER, STEINHEIMER & McGEE LLP 555 University Avenue, Suite 200 East Sacramento, CA 95825 Tel: [phone] Fax: [phone] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff JENNIFER ZAMORA UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

JENNIFER ZAMORA, Plaintiff, v. JANET NAPOLITANO, SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY; GALE ROSSIDES, ASSISTANT SECRETARY/ACTING ADMINISTRATOR OF THE TRANSPORTATION SECURITY ADMINISTRATION; LOREN ISHII; and DOES 1-20, Defendants.

Case No.: 2:09-CV-1292-JAM-EFB STIPULATION AND ORDER REGARDING TIMING FOR PLAINTIFF'S EXPERT WITNESS DISCLOSURES EXPERT DISCLOSURE DATE: 9/10/10

STIPULATION The parties, by and through their attorneys of record herein, stipulate and agree as follows: 1. The pretrial order in this case, filed by the Court on August 25, 2009, sets the date by

which Plaintiff Jennifer Zamora must file her expert witness disclosures on September 10, 2010. 2. Plaintiff states that, because of unanticipated delays in determining whether one of the

expert witnesses will be available to testify in this case, she seeks a one week extension of time, until September 17, 2010, to file the disclosures. /// -1-

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STIPULATION AND ORDER REGARDING TIMING FOR PLAINTIFF'S EXPERT DISCLOSURES

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3.

Defendants will agree to an extension of time to September 17, 2010, solely with

respect to the one expert witness whose availability is in question, on the following conditions: a. On September 10, 2010, plaintiff must file a disclosure which identifies by name

the one expert witness whose availability is in question; b. If the one expert witness whose availability is in question has already prepared

his or her expert report, that report must also be filed on September 10, 2010, subject to withdrawal should plaintiff determine that the witness is in fact unavailable to testify in this case; and c. Plaintiff must timely file expert witness disclosures and reports for any and all

other expert witnesses she intends to offer in this case on September 10, 2010. Respectfully submitted, Dated: September 10, 2010 ELLIS, LAVOIE, POIRIER, STEINHEIMER & MCGEE LLP By /s/ Teresa L. Zuber Teresa L. Zuber Attorney for Plaintiff JENNIFER ZAMORA Dated: September 10, 2010

BENJAMIN B. WAGNER UNITED STATES ATTORNEY By /s/ Jason Ehrlinspiel Jason Ehrlinspiel Assistant United States Attorney Attorneys for Defendants ORDER

IT IS SO ORDERED. Dated: 9/10/2010 /s/ John A. Mendez________________ HONORABLE JOHN A. MENDEZ UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER REGARDING TIMING FOR PLAINTIFF'S EXPERT DISCLOSURES