Keehner v. Jackson Laboratory

Filing 11

STIPULATION and ORDER 10 to continue deadlines signed by Judge William B. Shubb on 1/9/2012. Parties shall disclose experts and produce reports by no later than 2/17/2012. All Discovery shall be completed by 3/29/2012. (Marciel, M)

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SHAW VALENZA LLP
D. Gregory Valenza, Bar No. 161250
[e-mail]
Amy K. Lee, Bar No. 244542
[e-mail]
300 Montgomery Street, Suite 788
San Francisco, California 94104
Telephone: [phone]
Facsimile: (415) 983-596
Attorneys for Defendant
The Jackson Laboratory
Leo F. Donahue, Esq.
Leo F. Donahue, Inc.
[e-mail]
11344 Coloma Road, Suite 160
Gold River, CA 95670
Tele: [phone]
Fax: [phone]
Kevin W. Harris, Esq.
Law Offices of Kevin W. Harris
[e-mail]
11344 Coloma Road, Suite 160
Gold River, CA 95670
Tele: [phone]
Fax: [phone]
Attorneys for Plaintiff Kelly Keehner
UNITED STATES DISTRICT COURT - EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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KELLY KEEHNER,

Case No. 2:11-cv-01954-WBS-EFB

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Plaintiff,v.
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THE JACKSON LABORATORY, a
Corporation of unknown origin; and DOES
1 through 100, inclusive,

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Defendants.

STIPULATION AND [PROPOSED]
ORDER TO CONTINUE DISCOVERY
AND EXPERT DISCLOSURE DEADLINES
[E.D. Cal. L. R. 137; 143]
Courtroom 5
Judge:
Hon. William B. Shubb

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Plaintiff KELLY KEEHNER ("Plaintiff") and Defendant THE JACKSON

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LABORATORY ("Defendant"), by and between their respective attorneys of record, hereby

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stipulate as follows:

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1.

On September 20, 2011, the parties filed a Joint Status Report with this Court,

agreeing and requesting that the discovery cut-off occur 90 days before trial.

S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY AND EXPERT
DISCLOSURE DEADLINES

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2.

On October 28, 2011, this Court issued a Pretrial Scheduling Order, setting the

trial date for August 28, 2012.
3.

The Pretrial Scheduling Order also set the expert disclosure deadline for no later

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than January 17, 2012, which is 7 months before the scheduled trial date. The Pretrial

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Scheduling Order further set the completion of discovery for no later than February 29, 2012,

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which is 6 months before the scheduled trial date.

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4.

The parties have had insufficient opportunity to propound necessary discovery and

take depositions in preparation for a Motion for Summary Judgment or Trial.
5.

The parties have not yet received all of Plaintiff's medical records to provide to

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experts and have had insufficient opportunity to obtain expert reports before the January 17, 2012

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deadline.

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6.

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A brief 30 day continuance of the deadlines is necessary in order for both parties to

obtain the information necessary to prepare a Motion for Summary Judgment or for Trial.
7.

Pursuant to Local Rules 137 and 143, as well as Section IX of the Pretrial

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Scheduling Order, the parties agree to a continuance of the expert disclosure and reports cut-off to

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February 17, 2012 and discovery cut-off to March 29, 2012.

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SO STIPULATED:

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Dated: January 6, 2012

SHAW VALENZA LLP

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By: s/D. Gregory Valenza_
D. Gregory Valenza
Amy K. Lee
Attorneys for Defendant
THE JACKSON LABORATORY

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Dated: January 6, 2012

LEO F. DONAHUE, INC.
LAW OFFICES OF KEVIN W. HARRIS

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By: s/Leo F. Donahue_
Leo F. Donahue
Kevin W Harris
Attorneys for Plaintiff
Kelly Keehner

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY AND EXPERT
DISCLOSURE DEADLINES

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ORDER

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Pursuant to the parties' Stipulation, and GOOD CAUSE APPEARING therefore:

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IT IS HEREBY ORDERED that the parties shall disclose experts and produce reports by

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no later than February 17, 2012.
IT IS FURTHER ORDERED that all discovery shall be completed by March 29, 2012.

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DATED: January 9, 2012

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208686.1.00594.004

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S HAW V ALENZA LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER TO
CONTINUE DISCOVERY AND EXPERT
DISCLOSURE DEADLINES