Samuels v. Owens-Brockway Glass Container Inc.

Filing 21

STIPULATION and ORDER 20 to continue disclosure deadline signed by Judge Garland E. Burrell, Jr. on 6/13/2014. Initial Expert Disclosure deadline is CONTINUED to 8/22/2014. Rebuttal Expert Disclosure now due 9/12/2014. (Marciel, M)

SANDRA J. COHEN, CA SB#. 85045
300 South First Street, Suite 320
2
San Jose CA 95113
408-975-0545
3
[e-mail]
4
Attorney for Plaintiff ELIZABETH SAMUELS
5
SCHIFF HARDIN LLP
6 Stephen M. Hankins (CSB #154886)
[e-mail]
7
Sarah D. Youngblood (CSB #244304)
8 [e-mail]
One Market Plaza, Spear Street Tower
9 Thirty-Second Floor
San Francisco, CA 94015
10 Telephone: [phone]
Facsimile: 415-901-8701
11
1

12 Attorneys for Defendant
OWENS-BROCKWAY GLASS CONTAINER INC.
13
UNITED STATES DISTRICT COURT
14
EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION
15
16
17

ELIZABETH SAMUELS,
Plaintiff,

18

vs.
19 OWENS-BROCKWAY GLASS
CONTAINER, INC. and DOES I through V,
20
Defendants.
21
22

CASE NO. 2:13-CV-00713-GEB-DAD
STIPULATION AND [PROPOSED]
ORDER TO EXTEND EXPERT
DISCLOSURE DEADLINES
Judge: Honorable Garland E. Burrell

The parties, by and through their attorneys of record have met and conferred and agreed to

23 the following stipulation:
24

(1)

On July 8, 2013, the Court entered its Pretrial Scheduling Order setting the

25 discovery and trial schedule in this matter. See Docket No. 11.
26

(2)

Pursuant to this order, the close of fact discovery is not until October 14, 2014 and

27 trial is scheduled for May 19, 2015. Id.
28

(3)

On January 15, 2014, pursuant to the parties’ stipulation, the Court entered an order

2:13-CV-00713-GEG-DAD
1
STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCLOSURE DEADLINES

1 extending the deadline to disclose expert witnesses to July 8, 2014 and extending the deadline to
2 disclose rebuttal expert witnesses to August 5, 2014. See Docket No. 15.
3

(4)

The parties have each served written discovery on each other, met and conferred

4 multiple times regarding their respective responses and have informally resolved most of their
5 discovery disputes. Plaintiff’s deposition has been taken and Plaintiff plans to take depositions in
6 July.
7

(5)

Given the current status of discovery in this case, the fact that the close of

8 discovery is not until October 14, 2014, and that the parties would like to complete as much
9 factual discovery as possible before deposing expert witnesses, the parties have met and conferred
10 and agreed that a further extension of the deadlines to exchange initial and expert disclosures
11 would be in the best interest of each party.
12

Therefore, the parties have agreed to and propose an extension of the initial expert

13 disclosure deadline from July 8, 2014 to August 22, 2014 and an extension of the rebuttal expert
14 disclosure deadline from August 5, 2014 to September 12, 2014.
15

IT IS SO STIPULATED.

16 Dated: June 12, 2014

SANDRA J. COHEN

17

19

By: /s/ Sandra J. Cohen
Sandra J. Cohen
Attorneys for Plaintiff
ELIZABETH SAMUELS

20 Dated: June 12, 2014

SCHIFF HARDIN LLP

18

21
By: /s/ Sarah D. Youngblood (approved 6/12/12)
Sarah D. Youngblood
Attorneys for Defendant
OWENS-BROCKWAY GLASS
CONTAINER INC.

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23
24

25 PURSUANT TO STIPULATION, IT IS SO ORDERED.
26 Dated: June 13, 2014
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2:13-CV-00713-GEG-DAD
2
STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCLOSURE DEADLINES