Best Buy Stores, L.P. v. LF2 Rock Creek LP

Filing 42

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 2/13/15 ORDERING that the deadlined for Discovery is EXTENDED to 3/30/2015 for the limited purpose of taking the deposition of Best Buy's Rule 30(b)(6) designee(s) pursuant to the deposition notice already served by Defendant. Initial Expert Witness Disclosures deadline is EXTENDED to 4/15/2015. (Mena-Sanchez, L)

1
2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

BEST BUY STORES, L.P.,

12

Plaintiff,

13

v.

14

LF2 ROCK CREEK LP,

15

Case No. 2:13-CV-00433-MCE-AC
STIPULATION AND ORDER TO EXTEND
FACT AND EXPERT DISCOVERY
DEADLINES IN PRETRIAL SCHEDULING
ORDER

Defendant.

16
17

Complaint Filed:
Trial Date:

18

March 5, 2013
July 13, 2015

19

Plaintiff BEST BUY STORES, L.P., and Defendant LF2 ROCK CREEK LP (collectively, the

20

“Parties”), by and through their respective undersigned counsel and subject to this Court’s approval,

21

hereby stipulate and agree and request the approval of the Court to continue the fact and expert witness

22

disclosure deadlines (currently set for February 1, 2015 and February 20, 2015, respectively) for an

23

approximately one month as set forth below.

24

1.

March 30, 2015: Fact discovery cut off for the limited purpose of taking the deposition of

25

Best Buy’s Rule 30(b)(6) designee(s) pursuant to the deposition notice already served by

26

Defendant.

27

2.

April 15, 2015: Initial expert witness disclosures.

28

The Court is requested to approve these extensions on the following bases:
1
STIPULATION AND ORDER TO EXTEND FACT AND EXPERT DISCOVERY DEADLINES IN PRETRIAL
SCHEDULING ORDER
Case No. 2:13-CV-00433-MCE-AC

1

1) Having received the Court’s Order on the Parties respective Motions for Summary Judgment

2

that resolved at least one issue in the case, the Parties are schedule for mediation before Judge

3

Kleinberg of JAMS on February 10, and wish to complete mediation before incurring

4

additional expense related to fact and expert discovery and to postpone the depositions of

5

30(b)(6) witness and the expert disclosure deadline.
2) The requested extensions do not impact any other deadlines set forth in the Court’s Pretrial

6

Scheduling Order.

7
8

3) Four previous extensions have been requested by the Parties to the Court.

9

4) Trial is not set until July 13, 2015.

10

///

11

///

12

///

13

///

14

///

15

///

16

///

17

///

18

///

19

///

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///
2
STIPULATION AND ORDER TO EXTEND FACT AND EXPERT DISCOVERY DEADLINES IN PRETRIAL
SCHEDULING ORDER
Case No. 2:13-CV-00433-MCE-AC

1
2
3

IT IS HEREBY STIPULATED and the parties request that the following deadlines be extended
by approximately one month, with the new deadlines set forth below:
1.

March 30, 2015: Fact discovery cut off for the limited purpose of taking the deposition of

4

Best Buy’s Rule 30(b)(6) designee(s) pursuant to the deposition notice already served by

5

Defendant.

6

2.

April 15, 2015: Initial expert witness disclosures.

7
8

DATED: January 30, 2015

9

ROBINS, KAPLAN, MILLER & CIRESI L.L.P.

10

By: /s/ Michael A. Geibelson (as authorized on 1/30/2015
Michael A. Geibelson, Esq.

11

Attorneys for Plaintiff Best Buy Stores, L.P.

12
13

DATED: January 30, 2015

GREENBERG TRAURIG, LLP

14

16

By: /s/ Cindy Hamilton_____________________
William J. Goines
Cindy Hamilton
Alice Y. Chu

17

Attorneys for Defendant LF2 Rock Creek LP

15

18
19

ORDER

20
21
22

PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: February 13, 2015

23
24
25
26
27
28
3
STIPULATION AND ORDER TO EXTEND FACT AND EXPERT DISCOVERY DEADLINES IN PRETRIAL
SCHEDULING ORDER
Case No. 2:13-CV-00433-MCE-AC