Century 21 Real Estate, LLC v. All Professional Hawaii Realty, Inc. et al

Filing 41

STIPULATION and ORDER signed by Judge William B. Shubb on 3/16/2012: The deadline to disclose experts and produce reports shall be continued to 5/2/2012. The deadline to disclose rebuttal experts and their reports shall be continued to 5/31/2012. The deadline to complete all discovery (including the resolution of any discovery disputes) is continued to 6/18/2012.(Kirksey Smith, K)

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KAREN M. GOODMAN SBN: 117423
VIRGINIA CALE SBN: 258557
GOODMAN & ASSOCIATES
3840 Watt Avenue, Building A
Sacramento, CA 95821
Telephone No: [phone]
Facsimile No: [phone]
[e-mail]
[e-mail]
Attorney for Defendants STEVE WRIGHT; CAROL WRIGHT; ALL PROFESSIONAL
REALTY, INC.; and ALL PROFESSIONAL HAWAII REALTY, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CENTURY 21 REAL ESTATE, LLC, a
Delaware Limited Liability Company
formerly known as Century 21 Real
Estate Corporation,

)
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Plaintiff,
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vs.
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ALL PROFESSIONAL REALTY, INC., a )
California corporation doing business as )
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CENTURY 21 ALL PROFESSIONAL;
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STEVEN M. WRIGHT, an individual;
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and CAROL WRIGHT, an individual,
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Defendants.
__________________________________)

Case No: 2:10-cv-2751 WBS GGH
Consolidated with Case Nos. 2:10cv-2846 WBS GGH and 2:11-cv02497 WBS GGH
REVISED STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
PRE-TRIAL SCHEDULING DATES

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TO THE COURT, ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

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Plaintiff Century 21 Real Estate, LLC and Defendants All Professional Realty,

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Inc., All Professional Hawaii Realty, Inc., Steve M. Wright and Carol Wright, by and

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through their attorneys of record, stipulate and request that the pre-trial scheduling

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dates be continued to allow the parties to participate in mediation in good faith before

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mediator Lori Gualco on April 12, 2012. The dates were previously continued by order
Revised Stipulation and Order to Continue
Pre-Trial Scheduling Dates

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Century 21 Real Estate v. All Professional
Case No: 2:10-CV-2751

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dated February 16, 2012, but the stipulation filed was not the final agreed upon

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stipulation (due to an error by filing counsel) and failed to account for additional delay

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based upon the parties’ choice of mediator. A subsequent stipulation and order, setting

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the deadlines out further, was denied without prejudice by Magistrate Judge Gregory G.

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Hollows. The request for the continuance is due to the parties’ attempt to informally

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resolve this matter short of trial, through private mediation.

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participate in mediation, but would like to avoid incurring additional discovery costs at

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this time while pursuing full resolution of the matter. Based upon the denial of the

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previous stipulation and order without prejudice, the parties have revised the stipulation

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to avoid any potential interference with the currently scheduled pretrial conference and

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trial dates. Therefore, the parties stipulate to the following new and revised pre-trial

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schedule:

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1)

The parties desire to

The trial date shall remain set for October 30, 2012 at 9:00 a.m. in

Courtroom 5;
2)

The Final Pretrial Conference shall remain set for August 20, 2012 at 2:00

p.m. in Courtroom 5;
3)

The deadline for filing all motions, except motions for continuances,

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temporary restraining order, or other emergency applications, shall remain set for June

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18, 2012;

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4)

The deadline to complete all discovery (including the resolution of any

discovery disputes) shall be continued until June 18, 2012;
5)

The deadline to disclose experts and produce reports pursuant to Federal

Rule of Civil Procedure 26(a)(2) shall be continued until no later than May 2, 2012;
6)

The deadline to disclose rebuttal experts and their reports in accordance

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with Federal Rule of Civil Procedure 26(a)(2) shall be continued until no later than May

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31, 2012.

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Revised Stipulation and Order to Continue
Pre-Trial Scheduling Dates

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Century 21 Real Estate v. All Professional
Case No: 2:10-CV-2751

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Dated: 3/16/2012

By: _//s// Virginia Cale_____
Virginia Cale, (SBN: 258557)
GOODMAN & ASSOCIATES
Attorney for Defendants ALL
PROFESSIONAL REALTY, INC.,
ALL PROFESSIONAL HAWAII
REALTY, INC., STEVE M. WRIGHT
and CAROL WRIGHT
GOODMAN & ASSOCIATES
3840 Watt Avenue, Building A
Sacramento, CA 95821
Phone: [phone]

Dated: March 15, 2012

By: _//s// Aaron Rudin_______
Aaron Rudin (SBN: 155554)
GORDON & REES LLP
Attorney for Plaintiff CENTURY 21
REAL ESTATE, LLC
GORDON & REES LLP
633 West Fifth Street, Suite 4900
Los Angeles, CA 90071
Phone: [phone]

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IT IS SO ORDERED.
DATED: March 16, 2012

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Revised Stipulation and Order to Continue
Pre-Trial Scheduling Dates
RLGY/1064918/11754575v.1

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Century 21 Real Estate v. All Professional
Case No: 2:10-CV-2751