Meyer Manufacturing Company Limited v. Telebrands Corp.

Filing 50

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 11/07/12 ORDERING that any rebuttal expert disclosure shall be made by 01/07/13. (Benson, A.)

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HOLLAND & KNIGHT LLP
R. David Donoghue, Esq. (SBN 205730) (Counsel for Service)
131 South Dearborn Street, 30th Floor
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
HOLLAND & KNIGHT LLP
Matthew P. Vafidis (SBN 1003578)
50 California Street, 28th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff/Counter-Defendant
MEYER MANUFACTURING COMPANY LIMITED

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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MEYER MANUFACTURING COMPANY
LIMITED, a Hongkong Corporation,
Plaintiff,

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v.
TELEBRANDS CORP., a New Jersey
Corporation,
Defendant,

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CASE NO. 2:11-cv-03153 LKK-DAD

JOINT STIPULATION AND ORDER
TO ADD A REBUTTAL EXPERT
DISCLOSURE DATE TO THE
CURRENT CASE MANAGEMENT
SCHEDULE

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TELEBRANDS CORP., a New Jersey
Corporation,

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Counter-Plaintiff,

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v.

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MEYER MANUFACTURING COMPANY
LIMITED, a Hongkong Corporation, and
MEYER CORPORATION, U.S.,

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Counter-Defendants.

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Stipulation and Proposed Order to add a Rebuttal
Expert Disclosure Date to the Case Mgmt. Schedule

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CASE NO. 2:11-CV-03153 LKK-DAD

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Plaintiff/Counter-Defendant Meyer Manufacturing Company Limited, Counter-Defendant

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Meyer Corporation, U.S., and Defendant/Counter-Plaintiff Telebrands Corp., hereby stipulate and

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request that the Court modify its Scheduling Order to include a rebuttal expert disclosure deadline

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pursuant Rule 26(a)(2)(D)(ii) of the Federal Rules of Civil Procedure.
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The Court issued its Scheduling Order on May 31, 2012, and ordered that the parties serve

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upon all other parties by November 30, 2012 a final list of the names of all experts that they

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propose to tender at trial and the experts' written reports. Scheduling Order at 5 [Dkt. No. 39].

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The Scheduling Order, however, does not include a rebuttal expert disclosure deadline, pursuant

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to Rule 26(a)(2)(D)(ii) of the Federal Rules of Civil Procedure.
The parties have conferred and agreed to request that the Scheduling Order be amended as

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follows:

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On or before January 7, 2013, all counsel are to designate in writing and file with the court

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and serve upon all other parties a final list of the names of all rebuttal experts that they propose to

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tender at trial. At the time of designation, all rebuttal experts shall submit a written report. The

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contents of the report must comply with Federal Rule of Civil Procedure 26 (a)(2)(B). All rebuttal

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experts so designated are to be fully prepared to render an informed opinion at the time of

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designation so that they may fully participate in any deposition taken by the opposing party.
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WHEREFORE, in light of the foregoing, the parties respectfully request that the Court

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modify the current case management schedule embodied in its May 31, 2012 Scheduling Order to

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include a rebuttal expert disclosure deadline of January 7, 2013.

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Stipulation and Proposed Order to add a Rebuttal
Expert Disclosure Date to the Case Mgmt. Schedule

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CASE NO. 2:11-CV-03153 LKK-DAD

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Respectfully submitted,
By _/s/ R. David Donoghue______
Dated: November 05, 2012
HOLLAND & KNIGHT LLP
R. David Donoghue, Esq. (SBN 205730)
Michael A. Grill (Pro Hac Vice)
131 South Dearborn Street, 30th Floor
Chicago, Illinois 60603
Telephone: [phone]
Facsimile: [phone]

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HOLLAND & KNIGHT LLP
Matthew P. Vafidis (SBN 1003578)
50 California Street, 28th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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Counsel for Plaintiff and Counter-Defendant

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By: _/s/ Robert. T. Maldonado_____
Dated: November 05, 2012

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ROPERS, MAJESKI, KOHN & BENTLEY
Neil A. Smith, Esq. (SBN 63777)
50 West San Fernando Street, Suite 1400
San Jose, CA 95113-2429
COOPER & DUNHAM LLP
Peter D. Murray, Esq.
Robert T. Maldonado, Esq.
Hindy Dym, Esq.
30 Rockefeller Plaza
New York, New York 10112

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Counsel for Defendant

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So Ordered:

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Date: November 7, 2012
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Stipulation and Proposed Order to add a Rebuttal
Expert Disclosure Date to the Case Mgmt. Schedule

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CASE NO. 2:11-CV-03153 LKK-DAD