Blankenship v. Alaska Airlines, Inc.

Filing 17

STIPULATION and ORDER signed by Judge John A. Mendez on 1/7/2010 GRANTING 15 Stipulation and Proposed Order; Designation of Expert Witnesses due by 3/19/2010 and the date for exchange of rebuttal expert witness disclosure is extended to 4/16/2010. (Matson, R)

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CHRISTOPHER E. GRELL, ESQ. (SBN 88498) RICHARD F. RESCHO, ESQ. (SBN 108086) LAW OFFICES OF CHRISTOPHER E. GRELL The Leamington 1814 Franklin Street, Suite 501 Oakland, California 94612 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff ETHAN BLANKENSHIP ROBERT E. DAVIES, ESQ. (SBN 106810) MARY A. STEWART, ESQ. (SBN 106768) REBECCA WEINSTEIN-HAMILTON, ESQ. (SBN 162699) CAULFIELD, DAVIES & DONAHUE, LLP P.O. BOX 277010 Sacramento, CA 95827 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant ALASKA AIRLINES, INC.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA -o0oETHAN BLANKENSHIP, Plaintiff, v. ALASKA AIRLINES, INC., and Alaska Corporation, and DOES 1 through 100, inclusive, Defendants. IT IS HEREBY STIPULATED by and between Plaintiff ETHAN BLANKENSHIP and Defendant ALASKA AIRLINES, INC., through their respective counsel to extend the date for Exchange of Initial Expert Witness Disclosure and Reports, currently set for January 15, 2010, to March 19, 2010 and the date for Rebuttal Expert Disclosure currently set for February 12, 2010, to April 16, 2010.
STIPULATION TO EXTEND DATES FOR EXPERT WITNESS DISCLOSURE AND REPORTS; ORDER 1

Case No.: 2:09-CV-01377 JAM GGH The Hon. John A. Mendez STIPULATION TO EXTEND DATES FOR EXPERT WITNESS DISCLOSURES AND REPORTS; ORDER

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This stipulation is made by counsel for the parties, pursuant to the Honorable Judge John A. Mendez's Pre-Trial Scheduling Order of July 14, 2009 and U.S.D.C. Eastern District Local Rules, Rule 6-144. There is good cause for the requested extensions of the current dates for expert witness disclosures. Although considerable discovery has been completed to date, a

substantial amount of discovery remains in order to compile the necessary evidence to enable prospective experts to formulate their opinions. Plaintiff's action is for damages resulting from a fall in the security area of Sacramento International Airport. Plaintiff and Defendant have each served initial

Requests for Production and Requests for Admissions, and Defendant has served Interrogatories. Additionally, depositions have been taken of the Plaintiff and of witnesses who were in Plaintiff's traveling party. Plaintiff's counsel have requested dates for the depositions of Defendant Alaska Airlines, Inc.'s personnel. Plaintiff's medical records have been subpoenaed. Although counsel have not been dilatory in conducting discovery, additional discovery is needed in order to assemble the evidence necessary for prospective experts to formulate their opinions. Such discovery includes, but is not necessarily limited to,

depositions of Defendant Alaska Airlines, Inc. personnel, airport security personnel, and treating physicians, and inspection of the area where the fall occurred, as well as further interrogatories and requests for production. The parties agree that each party should be allowed adequate time to conduct necessary discovery into the matters at issue in this action, prior to expending the time and cost which would be required to meet the current expert witness disclosure requirements. The stipulated exension would allow the time needed. Both parties, through their respective counsel, have agreed that it would serve the interests of justice and judicial economy to extend the current expert disclosure dates to March 19, 2010 and April 16, 2010, as set forth above.

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STIPULATION TO EXTEND DATES FOR EXPERT WITNESS DISCLOSURE AND REPORTS; ORDER 2

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The requested extension of the current dates for expert witness disclosure would not affect the other dates set forth in the July 14, 2009 Pre-Trial Scheduling Order. WHEREFORE, the parties respectfully move this Honorable Court to extend the dates for expert witness disclosure as requested herein. Date: January _____, 2010 LAW OFFICES OF CHRISTOPHER E. GRELL

By:

______________________________________ RICHARD F. RESCHO Attorneys for Plaintiff ETHAN BLANKENSHIP CAULFIELD, DAVIES & DONAHUE, LLP

Date: January _____, 2010

By:

______________________________________ ROBERT E. DAVIES MARY A. STEWART Attorneys for Defendant ALASKA AIRLINES, INC.

ORDER EXTENDING DATES FOR EXPERT WITNESS DISCLOSURE IT IS HEREBY ORDERED, good cause appearing therefor, that the date for exchange of Initial Expert Witness Disclosure and Reports, currently set for January 15, 2010 is extended through March 19, 2010, and the date for exchange of Rebuttal Expert Witness Disclosure, currently set for February 12, 2010, is extended through April 16, 2010. IT IS SO ORDERED. Date: January 7, 2010 /s/ John A. Mendez____________ THE HON. JOHN A. MENDEZ United States District Court Judge

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STIPULATION TO EXTEND DATES FOR EXPERT WITNESS DISCLOSURE AND REPORTS; ORDER 3