USA v. Pacific Gas and Electric Company et al

Filing 34

ORDER signed by Judge John A. Mendez on 10/26/10 ORDERING expert disclosure due 12/15/10; supplemental expert disclosure due 12/30/10 and discovery completed by 2/4/11; all other dates of the 1/510 State Order remain the same.(Carlos, K)

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CARLSON CALLADINE & PETERSON LLP

RANDY W. GIMPLE [Bar No.: 12970 A.DAVID BONA [Bar No.: 209605] LYNDE SELDEN, III [Bar No. 207513] CARLSON, CALLADINE & PETERSON LLP 353 Sacramento Street, 16th Floor San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant DAVEY TREE SURGERY COMPANY ROBERT M. BLUM [Bar No. 083302] HAILEY R. HIBLER [Bar No. 229067] NIXON PEABODY LLP One Embarcadero Center, 18th Floor San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant DAVEY TREE SURGERY COMPANY

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353 SACRAMENTO STREET 16TH FLOOR San Francisco, CA 94111

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, vs. PACIFIC GAS & ELECTRIC COMPANY, DAVEY TREE SURGERY COMPANY, and THE DAVEY TREE EXPERT COMPANY, Defendants.

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Case No. 2:09-cv-02868-JAM-JFM

STIPULATION FOR ORDER MODIFYING STATUS ORDER

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, requested by Defendants Davey Tree Surgery Company and the Davey Expert Company, would only change the dates for disclosing experts and for completing
STIPULATION FOR ORDER MODIFYING STATUS ORDER CASE NO.: 2:09-CV-02868-JAM-JFM

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CARLSON CALLADINE & PETERSON LLP

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 proposed changes would not change the dates scheduled for pre-trial conference or trial of this case: 1. 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 November 15, 2010 November 30, 2010 January 5, 2011

NEW DATE December 15, 2010 December 30, 2010 February 4, 2011

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353 SACRAMENTO STREET 16TH FLOOR San Francisco, CA 94111

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: October 26, 2010 BENJAMIN B. WAGNER United States Attorney By: /s/ E. Robert Wright E. ROBERT WRIGHT Attorneys for Plaintiff UNITED STATES OF AMERICA 2
STIPULATION FOR ORDER MODIFYING STATUS ORDER

2. 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: October 26, 2010 CARLSON, CALLADINE & PETERSON LLP By: /s/ Lynde Selden, III RANDY W. GIMPLE A. DAVID BONA LYNDE SELDEN, III Attorneys for Defendant, DAVEY TREE SURGERY COMPANY

CASE NO.: 2:09-CV-02868-JAM-JFM

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CARLSON CALLADINE & PETERSON LLP

DATED: October 26, 2010

NIXON PEABODY LLP By: /s/ Robert M. Blum ROBERT M. BLUM HAILEY R. HIBLER Attorneys for Defendants, DAVEY TREE SURGERY COMPANY

DATED: October 26, 2010

FERRIS & BRITTON, A PROFESSIONAL CORPORATION By: /s/ Michael R. Weinstein MICHAEL R. WEINSTEIN Attorneys for Defendant PACIFIC GAS AND ELECTRIC COMPANY

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353 SACRAMENTO STREET 16TH FLOOR San Francisco, CA 94111

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STIPULATION FOR ORDER MODIFYING STATUS ORDER

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.

Dated: October 26, 2010 /s/ John A. Mendez____________ HON. JOHN A. MENDEZ U.S. DISTRICT COURT JUDGE

CASE NO.: 2:09-CV-02868-JAM-JFM

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