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

Filing 25

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 7/1/10 ORDERING that the deadline to disclose expert witnesses is extended to 9/1/10; rebuttal deadline extended to 10/1/10; the deadline to complete all non-expert discovery is extended to 12/1/10. (Owen, K)

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

Doc. 25

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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.
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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

Dockets.Justia.com

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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 November 1, 2010 and related discovery deadlines in paragraph IV of this Court's Status (Pretrial Scheduling Order) dated October 29, 2009 and the Parties' Stipulation and Joint Application to Extend Discovery Cutoff and Order Thereon dated February 25, 2010 (the "Orders"), and that the Court further 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 Pretrial Scheduling 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. Counsel for the Parties have since diligently engaged in discovery in a cooperative manner, but believe that due to the number of parties and the nature and complexity of issues in the case, additional time to complete discovery is necessary to prepare the case for trial and/or position the case for informal resolution. Consequently, good cause exists for continuing the discovery deadlines set forth in the Orders as follows: (1) The deadline of August 2, 2010 to disclose experts and produce reports in accordance with Federal Rule of Civil Procedure 26(a)(2) shall be vacated and continued to September 1, 2010; (2) The deadline of September 1, 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 October 1, 2010; and (3) The deadline of November 1, 2010 to complete all non-expert discovery, including depositions for preservation of testimony, shall be vacated and continued to December 1, 2010.
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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

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IT IS SO STIPULATED. Date: June 23, 2010 MICHAEL COGAN, ATTORNEY AT LAW

By: /s/ Michael Cogan (authorized 06/01/10) 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: June 23, 2010 NAGELEY, MEREDITH AND MILLER

By: /s/ Andrea Miller (authorized 06/01/10) 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

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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

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Date: June 23, 2010

JACKSON LEWIS LLP

By: /s/ Jerry J. Deschler, Jr. 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 August 2, 2010 to disclose experts and produce reports in accordance with Federal Rule of Civil Procedure 26(a)(2) shall be vacated and continued to September 1, 2010; (2) The deadline of September 1, 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 October 1, 2010; and (3) The deadline of November 1, 2010 to complete all non-expert discovery, including depositions for preservation of testimony, shall be vacated and continued to December 1, 2010.

Dated July 1, 2010 _____________________________________ CRAIG M. KELLISON UNITED STATES MAGISTRATE JUDGE

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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