USA v. Pacific Gas and Electric Company et al

Filing 44

STIPULATION and ORDER signed by Judge John A. Mendez on 05/10/11 ORDERING that deadlines are CONTINUED as follows: Expert Discovery cutoff: 07/08/11; pretrial statements due 07/15/11; Final Pretrial Conference set for 07/22/11 at 11:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez; Trial set for 08/29/11 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Benson, A.)

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BENJAMIN B. WAGNER
United States Attorney
GLEN F. DORGAN
Assistant United States Attorney
United States Courthouse
2500 Tulare Street, Suite 4401
Fresno, California 93721
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff, UNITED STATES OF AMERICA

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IN THE UNITED STATES DISTRICT COURT FOR THE

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EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,

)
)
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Plaintiff,
)
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v.
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)
PACIFIC GAS & ELECTRIC
)
COMPANY, DAVEY TREE SURGERY )
COMPANY, and THE DAVEY TREE
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EXPERT COMPANY,
)
)
)
Defendants.
)
)
__________________________________ )

Case No.: 2:09-cv-02868 JAM-JFM
STIPULATION AND ORDER CONTINUING
TRIAL DATE AND RELATED DEADLINES

Current Trial Date:
Current PTC Date:

July 11, 2011
June 3, 2011

For the reasons set forth in the accompanying Declaration of Glen F. Dorgan, Plaintiff,

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United States of America, and Defendants, Pacific Gas & Electric Company, and Davey Tree

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Surgery Company, through their counsel of record, stipulate as follows:
1.

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The parties request a continuance of the following dates and deadlines:
Current Date

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New Date

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Expert discovery Cut-off

May 13, 2011

July 8, 2011

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Filing of Pre-trial Statements

May 27, 2011

July 15, 2011

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Pre-Trial Conference

June 3, 2011 (3:00 p.m.)

July 22, 2011 (11:00 a.m.)

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Trial

July 11, 2011 (9:00 a.m.)

August 29, 2011 (9:00 a.m.)

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____________________________________________________________________________
STIPULATION AND PROPOSED ORDER CONTINUING TRIAL DATE AND RELATED DEADLINES

2.

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To the extent Plaintiff seeks and recovers pre-judgment interest at trial, the

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period for any calculation of interest shall not extend past the original trial date of April 11,

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2011.

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3.

As noted in the prior stipulations for an order modifying the scheduling order, the

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parties stipulate and agree that no party will file any dispositive motion and all parties have

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waived their right to file dispositive motions.
Respectfully submitted,

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BENJAMIN B. WAGNER
United States Attorney

Dated: May 10, 2011

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By:

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Dated: May 10, 2011

/s/ Glen F. Dorgan
GLEN F. DORGAN
Assistant United States Attorney
Attorney for Plaintiff
UNITED STATES OF AMERICA
CARLSON, CALLADINE & PETERSON, LLP

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By:

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/s/ Randy W. Gimple
RANDY W. GIMPLE
A. DAVID BONA
Attorneys for Defendant,
DAVEY TREE SURGERY COMPANY

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Dated: May 10, 2011

NIXON PEABODY, LLP

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By :

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/s/ Robert M. Blum
ROBERT M. BLUM
Attorneys for Defendant
DAVEY TREE SURGERY COMPANY

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Dated: May 10, 2011

FERRIS & BRITTON
A PROFESSIONAL CORPORATION

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By:

/s/ Michael R. Weinstein
MICHAEL R. WEINSTEIN
Attorneys for Defendant,
PACIFIC GAS AND ELECTRIC COMPANY

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____________________________________________________________________________
STIPULATION AND PROPOSED ORDER CONTINUING TRIAL DATE AND RELATED DEADLINES

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BENJAMIN B. WAGNER
United States Attorney
GLEN F. DORGAN
Assistant United States Attorney
United States Courthouse
2500 Tulare Street, Suite 4401
Fresno, CA 93721
Telephone: [phone]
Facsimile: [phone]
Attorneys for the Plaintiff
United States of America

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,

)
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Plaintiff,
)
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v.
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PACIFIC GAS & ELECTRIC COMPANY, )
DAVEY TREE SURGERY COMPANY, )
and THE DAVEY TREE EXPERT
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COMPANY,
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Defendants.
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____________________________________)

ORDER CONTINUING
TRIAL DATE AND RELATED
DEADLINES

Based upon the stipulation of the parties, and good cause appearing therefore, IT IS

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CASE NO: 2:09-cv-02868 JAM-JFM

HEREBY ORDERED that the trial date and related deadlines be moved out as follows:
Current Date

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New Date

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Expert discovery Cut-off

May 13, 2011

July 8, 2011

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Filing of Pre-trial Statements

May 27, 2011

July 15, 2011

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Pre-Trial Conference

June 3, 2011 (3:00 p.m.)

July 22, 2011 (11:00 a.m.)

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Trial

July 11, 2011 (9:00 a.m.)

August 29, 2011 (9:00 a.m.)

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IT IS SO ORDERED.

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DATED: 5/10/2011
/s/ John A. Mendez
HONORABLE JOHN A. MENDEZ
UNITED STATES DISTRICT JUDGE
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____________________________________________________________________________
STIPULATION AND PROPOSED ORDER CONTINUING TRIAL DATE AND RELATED DEADLINES