Martinez, et al., v. SCC Florin Road Bingo, et al.,

Filing 26

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr. on 3/10/2011 ORDERING that the expert disclosure deadlines are continued as follows: Expert Disclosure due 3/28/2011 and Supplemental Expert Disclosure due 4/28/2011. (Zignago, K.)

Martinez, et al., v. SCC Florin Road Bingo, et al.,

Doc. 26

1 PAUL L. REIN, Esq. (SBN 43053)

2 CATHERINE M. CABALO (SBN 248198) 3 200 Lakeside Drive, Suite A 4 Telephone: [phone]

CELIA McGUINNESS, Esq. (SBN 159420) LAW OFFICES OF PAUL L. REIN Oakland, CA 94612 Facsimile: [phone] Attorneys for Plaintiffs JOSE MARTINEZ

5

6 CONNIE MARTINEZ and 7 8 GREVE, CLIFFORD, WENGEL & PARAS, LLP

Sacramento, CA 95833-4324 [e-mail] Telephone: [phone] Facsimile: [phone]
10 E-Mail: 12 Attorneys for Defendants 13 dba Florin Road Bingo, incorrectly sued as

9 2870 Gateway Oaks Drive, Suite 210

SCOTT E. COFER, Esq. (SBN 121212)

SACRAMENTO CONSOLIDATED CHARITIES, SCC FLORIN ROAD BINGO; KEVIN BEERS; identified following caption]

14 and SHAW MARTINEZ, incorrectly sued as SHAWN MARTINEZ 15 [Counsel for additional Defendant 16 17 18 19 CONNIE MARTINEZ and

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA JOSE MARTINEZ, v. STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL DEADLINES FOR INITIAL EXPERT WITNESS DISCLOSURE REPORTS AND SUPPLEMENTAL EXPERT DISCLOSURE REPORTS CASE NO. 2:10-cv-01647 GEB-GGH GEB-GGH Civil Rights

20 21 22 23

Plaintiffs,

SCC FLORIN ROAD BINGO; 24 SACRAMENTO CONSOLIDATED CHARITIES; KEVIN BEERS; 25 SHAWN MARTINEZ; ARC PROPERTIES, INC.; AND DOES 26 1-10, INCLUSIVE,
27 28
L A W O F F IC E S O F

Defendants. /
STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL DEADLINES FOR INITIAL EXPERT WITNESS DISCLOSURE REPORTS AND SUPPLEMENTAL EXPERT DISCLOSURE REPORTS 2:10-cv-01647 GEB-GGH

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A O A K L A N D , C A 94612-3503 [phone]

-1Dockets.Justia.com

1 LEWIS, BRISBOIS, BISGAARD 2 MELISSA T. OMANSKY, Esq. (SBN 227451) 3 Los Angeles, CA 90012

& SMITH LLP E-Mail:

221 North Figueroa Street, Suite 1200 [e-mail] Facsimile: (213) 2507900 Attorneys for Defendant

4 Telephone: [phone]

6 ARC PROPERTIES, INC. 7

Plaintiffs CONNIE MARTINEZ and JOSE MARTINEZ and Defendants

8 SACRAMENTO CONSOLIDATED CHARITIES dba Florin Road Bingo 9 (incorrectly sued as SCC FLORIN ROAD BINGO), KEVIN BEERS, SHAW 10 MARTINEZ and ARC PROPERTIES, INC., by and through their respective counsel, 11 hereby jointly stipulate and request, through their attorneys of record, as follows: 12

The parties have been working cooperatively to settle injunctive relief aspects

13 of this case and believe that there is a good likelihood that the parties will be able to 14 settle all issues of injunctive relief, damages, and attorneys' fees, litigation expenses 15 and costs if given more time. Specifically, and with the expectation that it will 16 expedite settlement discussions, counsel for SACRAMENTO CONSOLIDATED 17 CHARITIES dba Florin Road Bingo (incorrectly sued as SCC FLORIN ROAD 18 BINGO) desires to circulate to counsel for Plaintiffs its expert report for review prior 19 to being required to file and serve its formal Expert Witness Disclosure 20 Statement/Reports. At the same time, counsel for the respective parties are also 21 proposing to stipulate to an early settlement conference to aid in settlement of the 22 claims of Plaintiffs if the parties feel that this Court's further involvement could 23 assist in the settlement efforts. 24

As a result of this settlement activity, counsel for the respective parties request

25 that the deadlines for the initial Expert Disclosure and Supplemental Expert 26 Disclosure be continued for an additional two (2) week period. 27 / / / 28 / / /
STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL DEADLINES FOR INITIAL EXPERT WITNESS
L A W O F F IC E S O F

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A O A K L A N D , C A 94612-3503 [phone]

DISCLOSURE REPORTS AND SUPPLEMENTAL EXPERT DISCLOSURE REPORTS 2:10-cv-01647 GEB-GGH

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1 2 3 4

The current deadlines in this case are as follows: Expert disclosure: Supplemental expert disclosure: March 14, 2011 April 12, 2011

Based on the above, the parties hereby agree and stipulate to the continuation Expert disclosure: Supplemental expert disclosure: IT IS SO STIPULATED. LAW OFFICES OF PAUL L. REIN By /s/ Catherine M. Cabalo CATHERINE M. CABALO, Esq. Attorneys for Plaintiffs CONNIE MARTINEZ and JOSE MARTINEZ March 28, 2011 April 28, 2011

5 of the above-noted deadlines in this case to the following: 6 7 8 9 10 11 12 Dated: March 9, 2011. 13 14 15 16 17 18 19 Dated: March 9, 2011. 20 21 22 23 24 25 26 Dated: March 10, 2011. 27 28
STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL DEADLINES FOR INITIAL EXPERT WITNESS
L A W O F F IC E S O F

GREVE, CLIFFORD, WENGEL & PARAS, LLP

By

/s/ Scott E. Cofer SCOTT E. COFER, Esq. Attorneys for Defendants SACRAMENTO CONSOLIDATED CHARITIES dba Florin Road Bingo, KEVIN BEERS and SHAW MARTINEZ

LEWIS, BRISBOIS, BISGAARD & SMITH LLP

By

/s/ Melissa T. Omansky MELISSA T. OMANSKY, Esq. Attorneys for Defendant ARC PROPERTIES, INC.

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A O A K L A N D , C A 94612-3503 [phone]

DISCLOSURE REPORTS AND SUPPLEMENTAL EXPERT DISCLOSURE REPORTS 2:10-cv-01647 GEB-GGH

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1 2

ORDER The Court grants the parties' stipulation, and pursuant to that stipulation Expert disclosure: Supplemental expert disclosure: March 28, 2011 April 28, 2011

3 continues the expert disclosure deadlines as follows: 4 5 6 7 Dated: March 10, 2011 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL DEADLINES FOR INITIAL EXPERT WITNESS
L A W O F F IC E S O F

GARLAND E. BURRELL, JR. United States District Judge

PAUL L. REIN
200 L A K E SID E D R ., S U I T E A O A K L A N D , C A 94612-3503 [phone]

DISCLOSURE REPORTS AND SUPPLEMENTAL EXPERT DISCLOSURE REPORTS 2:10-cv-01647 GEB-GGH

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