Korte v. Dollar Tree Stores, Inc.

Filing 28

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 1/11/13: Designation of Expert Witnesses continued from January 18, 2013 to February 15, 2013. (Kaminski, H)

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MAUREEN E. MCCLAIN, Bar No. 062050
Email: [e-mail]
MATTHEW P. VANDALL, Bar No. 196962
Email: [e-mail]
AIMÉE E. AXELROD, Bar No. 255589
Email: [e-mail]
LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
Telephone:
415.433.1940
Facsimile:
415.399.8490
Attorneys for Defendant
DOLLAR TREE STORES, INC. (erroneously
herein sued as DOLLAR TREE CORP.)

ROBERT P. BIEGLER, Bar No.
Email: [e-mail]
THE BIEGLER LAW FIRM
725 University Ave
Sacramento, CA 95825
Telephone:
916.927.3971
Facsimile:
916.927.7869
Attorneys for Plaintiff
EUGENE KORTE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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EUGENE KORTE,

Case No. 2:12−CV−00541−LKK−AC

Plaintiff,
v.
DOLLAR TREE CORP.,
Defendant.

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STIPULATION AND ORDER TO
CONTINUE EXPERT DISCLOSURE
DEADLINE

Complaint Filed:
FAC Filed:
Trial Date:

December 8, 2011
June 20, 2012
January 14, 2014

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE EXPERT DISCLSOURE DEADLINE

Case No.: 12−CV−00541−LKK−AC

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TO THE HONORABLE COURT AND TO ALL PARTIES AND COUNSEL:
Plaintiff Eugene Korte (“Plaintiff”) and Defendant Dollar Tree Stores, Inc.,
erroneously sued as Dollar Tree Corp. (“Defendant”) (collectively “Parties”), by and through their
attorneys of record stipulate as follows:
WHEREAS, the Court set the trial date in this matter for January 14, 2014;
WHEREAS, the Court previously ordered that discovery shall close on March 21,
2013 and that experts shall be designated sixty (60) days prior to the close of discovery (e.g., by
January 18, 2013);
WHEREAS, the Parties in good faith wish to explore the possibility of settlement
prior to the disclosure of their expert reports, if any;
WHEREAS, the Parties agree that a brief extension of the expert disclosure deadline
is in the interests of judicial economy and efficiency because the parties wish to explore the
possibility of settlement before incurring the costs associated with designating experts; and
WHEREAS, no other requests to continue deadlines have been sought or are being
sought by the Parties.
IT IS NOW HEREBY STIPULATED AND AGREED that:
The deadline to designate experts shall be extended from January 18, 2013 to
February 15, 2013.

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I HEREBY ATTEST THAT THE CONTENT OF THIS DOCUMENT IS ACCEPTABLE TO
ALL PERSONS REQUIRED TO SIGN THIS DOCUMENT
Dated: January 10, 2013

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By:/s/ Matthew P. Vandall
MATTHEW P. VANDALL
LITTLER MENDELSON, P.C.
Attorneys for Defendant
DOLLAR TREE STORES, INC.

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE EXPERT DISCLOSURE DEADLINE

2.

Case No.: 12−CV−00541−LKK−AC

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Dated: January 10, 2013

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By:/s/ Robert P. Biegler
ROBERT P. BIEGLER
THE BIEGLER LAW FIRM
Attorneys for Plaintiff
EUGENE KORTE

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ORDER ON STIPULATION
It is ORDERED that the deadline for designation of experts be continued from
January 18, 2013 to February 15, 2013.

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Dated: January 11, 2013.

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

STIPULATION AND [PROPOSED] ORDER TO
CONTINUE EXPERT DISCLOSURE DEADLINE

3.

Case No.: 12−CV−00541−LKK−AC