Carden et al v. Chenega Security & Protection Services, LLC

Filing 13

ORDER signed by Judge William B. Shubb on 2/25/2010 GRANTING 12 Stipulation and Proposed Order; The deadline of 7/1/2010 to disclose experts and produce reports shall be vacated and continued to August 2, 2010; The deadline of August 2, 2010 to dis close experts and produce reports for expert testimony intended solely for rebuttal shall be vacated and continued to September 1, 2010; and the deadline of October 1, 2010 to complete all non-expert discovery, including depositions for preservation of testimony, shall be vacated and continued to November 1, 2010. (Matson, R)

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

MICHAEL COGAN ATTORNEY AT LAW MICHAEL COGAN (SBN: 65479) 1388 Court Street, Suite E Redding, California 96001 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] NAGELEY, MEREDITH AND MILLER ANDREA MILLER (SBN: 88992) 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Attorneys for Plaintiffs JACKSON LEWIS LLP CARY G. PALMER (SBN 186601) DALE R. KUYKENDALL (SBN 148833) JERRY J. DESCHLER, JR (SBN 215691) 801 K Street, Suite 2300 Sacramento, California 95814 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] E-mail: [e-mail] E-mail: [e-mail] Attorneys for Defendant UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA JAMES T. CARDEN, JR., ROBERT L. FOX, LEON W. HEDERICK, ROBERT B. KLEE, GEORGE M. LEMBO, LOREN E. LOVELAND, TERRY D. MYERS, CHARLES R. SAMUELSON, MICHAEL B. SCHAFFER, ARTHUR J. SCHUBERT, THURLOW E. WILLIAMS, MICHELLE W. WOODS, RAYMOND E. YOUNG, WILLIAM H. ZIEGLER, Plaintiffs, v. CHENEGA SECURITY PROTECTION SERVICES, LLC, Defendant.
1
Stipulation And Joint Application To Extend Discovery Cut-Off; Order Thereon Carden, et al. v. Chenega Security Protection Services, LLC USDC ED Case No. 2:09-CV-01799-WBS-CMK

Case No. 2:09-CV-01799-WBS-CMK STIPULATION AND JOINT APPLICATION TO EXTEND DISCOVERY CUT-OFF; ORDER THEREON

Complaint Filed: Trial Date:

June 29, 2009 April 5, 2011

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 /// ///

Pursuant to Federal Rule of Civil Procedure 16(b)(4), and for good cause shown, the parties to this action, through their respective counsel of record, hereby stipulate and jointly request that the Court vacate the present discovery cut-off date of October 1, 2010 and related discovery deadlines in paragraph IV of this Court's Status (Pretrial Scheduling Order) dated October 29, 2009 (the "Order"), and that the Court continue such dates by approximately 30 days as set forth below. The requested continuances will have no impact on the motion hearing schedule, final pre-trial conference, and trial dates in paragraphs V, VI, and VII of the Order. THE PARTIES HEREBY STIPULATE AS FOLLOWS: WHEREAS Jackson Lewis LLP, counsel for Defendant Chenega Security & Protection Services, LLC ("Defendant"), has only recently substituted in as counsel of record for Defendant effective January 6, 2010, defense counsel had not yet been retained and did not participate in the Rule 26(f) conference and creation of the present discovery plan. Because Defense counsel has been counsel of record in this matter since January 6, 2010, defense counsel has not yet had a full and complete opportunity to familiarize itself with the file and legal issues in this matter or to complete its initial investigation. Consequently, good cause exists for continuing the discovery deadlines in paragraph IV of the Order as follows: (1) The deadline of July 1, 2010 to disclose experts and produce reports in accordance with Federal Rule of Civil Procedure 26(a)(2) shall be vacated and continued to August 2, 2010; (2) The deadline of August 2, 2010 to disclose experts and produce reports for expert testimony intended solely for rebuttal in accordance with Federal Rule of Civil Procedure 26(a)(2) shall be vacated and continued to September 1, 2010; and (3) The deadline of October 1, 2010 to complete all non-expert discovery, including depositions for preservation of testimony, shall be vacated and continued to November 1, 2010.

2
Stipulation And Joint Application To Extend Discovery Cut-Off; Order Thereon Carden, et al. v. Chenega Security Protection Services, LLC USDC ED Case No. 2:09-CV-01799-WBS-CMK

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

IT IS SO STIPULATED. Date: February 16, 2010 MICHAEL COGAN, ATTORNEY AT LAW

By: /s/ Michael Cogan (authorized February 16, 2010) Michael Cogan Attorneys for Plaintiffs JAMES T. CARDEN, JR., ROBERT L. FOX, LEON W. HEDERICK, ROBERT B. KLEE, GEORGE M. LEMBO, LOREN E. LOVELAND, TERRY D. MYERS, CHARLES R. SAMUELSON, MICHAEL B. SCHAFFER, ARTHUR J. SCHUBERT, THURLOW E. WILLIAMS, MICHELLE W. WOODS, RAYMOND E. YOUNG, WILLIAM H. ZIEGLER Date: February 18, 2010 NAGELEY, MEREDITH AND MILLER

By: /s/ Andrea Miller (authorized February 18, 2010) Andrea Miller Attorneys for Plaintiffs JAMES T. CARDEN, JR., ROBERT L. FOX, LEON W. HEDERICK, ROBERT B. KLEE, GEORGE M. LEMBO, LOREN E. LOVELAND, TERRY D. MYERS, CHARLES R. SAMUELSON, MICHAEL B. SCHAFFER, ARTHUR J. SCHUBERT, THURLOW E. WILLIAMS, MICHELLE W. WOODS, RAYMOND E. YOUNG, WILLIAM H. ZIEGLER

3
Stipulation And Joint Application To Extend Discovery Cut-Off; Order Thereon Carden, et al. v. Chenega Security Protection Services, LLC USDC ED Case No. 2:09-CV-01799-WBS-CMK

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

Date: February 25, 2010

JACKSON LEWIS LLP

By: /s/ Jerry J. Deschler Cary G. Palmer Dale R. Kuykendall Jerry J. Deschler, Jr. Attorneys for Defendant CHENEGA SECURITY PROTECTION SERVICES, LLC

Having reviewed the parties' stipulation, and good cause appearing therefore, IT IS HEREBY ORDERED: (1) The deadline of July 1, 2010 to disclose experts and produce reports in accordance with Federal Rule of Civil Procedure 26(a)(2) shall be vacated and continued to August 2, 2010; (2) The deadline of August 2, 2010 to disclose experts and produce reports for expert testimony intended solely for rebuttal in accordance with Federal Rule of Civil Procedure 26(a)(2) shall be vacated and continued to September 1, 2010; and (3) The deadline of October 1, 2010 to complete all non-expert discovery, including depositions for preservation of testimony, shall be vacated and continued to November 1, 2010. Dated: February 25, 2010

H:\C\Chenega Security & Protection Services (119612)\Carden, James (153464) CHUBB\Pleadings\Joint\003 pld Stip and Order re discovery deadlines.doc

4
Stipulation And Joint Application To Extend Discovery Cut-Off; Order Thereon Carden, et al. v. Chenega Security Protection Services, LLC USDC ED Case No. 2:09-CV-01799-WBS-CMK