USA v. Pacific Gas and Electric Company et al

Filing 32

STIPULATION and ORDER signed by Judge John A. Mendez on 7/21/2010 re 31 ORDERING that plaintiff may have until August 11, 2010 to respond to Davey Tree's Request for production of documents, set one and Interrogatories, set one. The following d ates set forth in the 14 Status Order are changed as follows: Designation of Expert Witnesses ddl 10/15/2010; Supplemental Expert Disclosure ddl 11/5/10; Discovery ddl 12/6/2010. All other scheduled dates remain the same including trial date of 4/11/2011. (Duong, D) Modified on 7/22/2010 (Duong, D).

USA v. Pacific Gas and Electric Company et al

Doc. 32

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BENJAMIN B. WAGNER United States Attorney E. ROBERT WRIGHT (SBN 51861) Assistant United States Attorney United States Courthouse 501 "I" Street, Suite 10-100 Sacramento, California 95814 Telephone: [phone] Facsimile: [phone] Of Counsel: JEFF MOULTON Regional Attorney RACHEL A. BIRKEY Attorney Office of the General Counsel United States Department of Agriculture 33 New Montgomery Street, 17th Floor San Francisco, California 94105 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff United States of America

13 14 15 16 UNITED STATES OF AMERICA, 17 Plaintiff, 18 v. 19 20 21 Defendants. 22 23 24 25 26 27 28 The parties through counsel hereby stipulate regarding scheduling as follows, including stipulation for an Order where necessary. The Status Order for this case was filed January 5, 2010 (Doc. 14). The proposed changes would only change the dates for disclosing experts and for completing discovery. The proposed changes are necessary to allow the parties sufficient time to allow experts to review factual discovery prior to preparing their expert reports. The 1
STIPULATION FOR ORDER MODIFYING STATUS ORDER

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) Case No. 2:09-cv-02868-JAM-JFM STIPULATION FOR ORDER MODIFYING STATUS ORDER

PACIFIC GAS AND ELECTRIC COMPANY, and DAVEY TREE SURGERY COMPANY,

Dockets.Justia.com

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proposed changes would not change the dates scheduled for pre-trial conference or trial of this case: 1. By stipulation, plaintiff may have until August 11, 2010 to respond to Davey Tree's Request for production of documents, set one and Interrogatories, set one. 2. By stipulation for an Order that the following dates set forth in the Status Order are changed as follows: CURRENT DATE Expert Disclosure: Supplemental Expert Disclosure: Discovery Completed August 16, 2009 September 6, 2009 October 4, 2010 NEW DATE October 15, 2010 November 5, 2010 December 6, 2010

3. All other scheduled dates in the Status Order of January 5, 2010 remain the same including the trial date of April 11, 2011.

Respectfully submitted, Dated: July __, 2010 BENJAMIN B. WAGNER United States Attorney By: /s/ E. Robert Wright E. ROBERT WRIGHT Assistant U.S. Attorney Attorneys for Plaintiff United States of America

Dated: July __, 2010 21 22 23 24 25 26 27 28

CARLSON, CALLADINE & PETERSON LLP By: RANDY W. GIMPLE, Esq. A. DAVID BONA, Esq. Attorneys for Defendant, DAVEY TREE SURGERY COMPANY

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STIPULATION FOR ORDER MODIFYING STATUS ORDER

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Dated: July __, 2010

NIXON PEABODY LLP By:

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ROBERT M. BLUM, Esq. HAILEY R. HIBLER, Esq. Attorneys for Defendant, DAVEY TREE SURGERY COMPANY FERRIS & BRITTON, A PROFESSIONAL CORPORATION

MICHAEL R. WEINSTEIN, Esq. Attorneys for Defendant, PACIFIC GAS AND ELECTRIC COMPANY

ORDER Based on the above Stipulation and good cause having been shown, IT IS HEREBY ORDERED that all current Status Order dates remain the same except that the dates for Expert Disclosure, Supplemental Expert Disclosure, and Discovery Completion are modified as set forth in the above Stipulation. IT IS SO ORDERED.

/s/ John A. Mendez HON. JOHN A. MENDEZ U. S. DISTRICT COURT JUDGE

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STIPULATION FOR ORDER MODIFYING STATUS ORDER