Norman v. The Salvation Army

Filing 22

STIPULATION and ORDER signed by Judge John A. Mendez on 11/12/10 ORDERING that pursuant to the parties' stipulation, the last day to depose retained experts Randall S. Stout, Chris Taylor, and Larry Wood, is Friday, 2/11/11. All other discovery, including depositions, shall be completed by 12/13/10 pursuant to the parties' stipulation and the Court's order of 10/22/10. (Becknal, R)

Norman v. The Salvation Army

Doc. 22

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STEVEN D. WERTH, # 121153 JENNY LI, # 216900 LOW, BALL & LYNCH 505 Montgomery Street, 7th Floor San Francisco, California 94111-2584 Telephone [phone] Facsimile [phone] Email: [e-mail] Email: [e-mail] Attorneys for Defendant THE SALVATION ARMY UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION LENORA NORMAN, ) ) Plaintiff, ) ) vs. ) ) THE SALVATION ARMY, a California ) Corporation, doing business as THE SALVATION ) ARMY ADULT REHABILITATION CENTER and ) THE SALVATION ARMY THRIFT STORE; ) DOES 1 through 50, inclusive, ) ) Defendants. ) ) ) Case No. 2:09-CV-03270-JAM-GGH STIPULATION AND ORDER FOR MUTUAL EXTENSION TO DEPOSE EXPERT WITNESSES Judge: Hon. John A. Mendez Magistrate Judge: Hon. Gregory G. Hollows Date Complaint Filed: October 22, 2009 Trial Date: April 18, 2011

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The parties herein, through their attorneys of record, hereby agree and stipulate to a mutual 20 extension of sixty (60) days to depose retained expert witnesses who were disclosed to render opinions 21 regarding plaintiff's claims under the American With Disabilities Act, California Unruh Act, and 22 California Disabled Persons Act. Such retained expert witnesses are Randall S. Stout and Chris Taylor 23 for plaintiff, and Larry Wood for defendant. All other discovery, including depositions, shall be 24 completed by December 13, 2010 pursuant to the parties' stipulation and the Court's order of October 25 22, 2010. 26 // 27 // 28 // -1S T I P U L A T I O N AND [PROPOSED] ORDER FOR MUTUAL EXTENSION TO DEPOSE EXPERT W I T N E S S E S
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Case No. 2:09-CV-03270-JAM-GGH

Dockets.Justia.com

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This stipulation and order are being sought to afford the parties the opportunity to resolve the aforementioned claims without having to incur the substantial attorneys fees associated with the depositions of the three retained experts disclosed for such claims. Accordingly, the last day to depose Mr. Stout, Mr. Taylor, and Mr. Wood is Friday, February 11, 2011.

Dated: November _____, 2010. LOW, BALL & LYNCH By /s/ STEVEN D. WERTH JENNY LI Attorneys for Defendant THE SALVATION ARMY

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ELLIS, LAVOIE, POIRIER, STEINHEIMER, & MCGEE, LLP

By /s/ THERESA M. LaVOIE Attorney for Plaintiff LENORA NORMAN

ORDER 20 It is hereby ordered that pursuant to the parties' stipulation, the last day to depose retained 21 experts Randall S. Stout, Chris Taylor, and Larry Wood, is Friday, February 11, 2011. All other 22 discovery, including depositions, shall be completed by December 13, 2010 pursuant to the parties' 23 stipulation and the Court's order of October 22, 2010. 24 IT IS SO ORDERED. 25 Dated: 11/12/2010 26 27 28 -2S T I P U L A T I O N AND [PROPOSED] ORDER FOR MUTUAL EXTENSION TO DEPOSE EXPERT W I T N E S S E S
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/s/ John A. Mendez JUDGE OF THE DISTRICT COURT

Case No. 2:09-CV-03270-JAM-GGH