Tat Tohumculuk A.S. v. H. J. Heinz Company, et al

Filing 49

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 7/18/14 ORDERING that the deadlines for discovery and motions set forth in the Status (Pretrial Scheduling) Order, are rescheduled as follows: Non-Expert Discovery Closes: Novembe r 14, 2014; Last Day to Disclose Experts and Produce Expert Reports: December 15, 2014; Last Day to Disclose Rebuttal Experts and Produce Expert Rebuttal Reports: January 15, 2015; Expert Discovery Closes: February 13, 2015; Last Day to File Motions, Except for Continuances, Temporary Restraining Orders, or Other Emergency Applications: February 13, 2015. (Becknal, R)

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ANASTASSIOU & ASSOCIATES
Effie F. Anastassiou (CA 96279)
Stephen J. Beals, Esq. (CA 226365)
242 Capitol Street
Post Office Box 2210
Salinas, CA 93902
Telephone: [phone]
Facsimile: 831.754.0621
Attorneys for Plaintiff
TAT TOHUMCULUK A. S.
IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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TAT TOHUMCULUK A. S., a Turkish
Company,

Case No:

2:13-CV-00773-WBS-KJN

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Plaintiff,

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STIPULATION AND [PROPOSED] ORDER
TO CONTINUE DISCOVERY DEADLINES

v.
H.J. HEINZ COMPANY, L.P. a Pennsylvania
Limited Partnership registered to do business
in California, and HEINZSEED, an
unincorporated division of H.J. HEINZ
COMPANY, L.P.,

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Defendants.

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Plaintiffs TAT Tohumculuk A.S. ("Plaintiff") and Defendants H.J. Heinz Company, L.P.,

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and Heinzseed, an unincorporated division of H.J. Heinz Company, L.P. (collectively,
"Defendants") (collectively, the "Parties") hereby submit, through their undersigned counsel of
record, the following Stipulation and Proposed Order:
WHEREAS, on January 15, 2014, this Court entered its Status (Pretrial Scheduling)

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Order1 (the “Scheduling Order”) which set forth, among other things, discovery and motion
deadlines in the above referenced matter;

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WHEREAS, the Parties previously postponed overseas depositions in order to conduct
informal settlement discussions which were not successful;

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ECF No. 41.

TAT TOHUMCULUK v. HEINZSEED

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Case No:2:13-CV-00773-WBS

STIPULATION AND ORDER TO CONTINUE DISCOVERY DEADLINES

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WHEREAS, the Parties wish to extend those deadlines set forth in the Scheduling

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Order as follows, in order to allow additional time for the parties to conduct depositions in

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foreign countries which require extensive time to schedule and coordinate;

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Deadline for:

Currently Scheduled
Deadline:

Proposed Rescheduled
Deadline

Non-Expert Discovery
Closes

September 30, 2014

November 14, 2014

Last Day to Disclose
Experts and Produce
Expert Reports

October 31, 2014

December 15, 2014

Last Day to Disclose
Rebuttal Experts and
Produce Expert Rebuttal
Reports

November 30, 2014

January 15, 2015

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Expert Discovery Closes

December 31, 2014

February 13, 2015

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Last Day to File Motions,
Except for
Continuances,
Temporary Restraining
Orders, or Other
Emergency Applications

December 31, 2014

February 13, 2015

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THEREFORE, IT IS HEREBY STIPULATED between counsel for Defendants and

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counsel for Plaintiff that the discovery and motion deadlines set forth in the Scheduling Order

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be rescheduled as set forth above.

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SO STIPULATED.

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Dated: June 24, 2014

ANASTASSIOU & ASSOCIATES

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By:

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/s/ Effie F. Anastassiou
Effie F. Anastassiou, Esq.
Attorneys for Plaintiff,
TAT TOHUMCULUK A. S.

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TAT TOHUMCULUK v. HEINZSEED

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Case No:2:13-CV-00773-WBS

STIPULATION AND ORDER TO CONTINUE DISCOVERY DEADLINES

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Dated: June 24, 2014

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REED SMITH LLP
By:

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/s/ David S. Reidy
David S. Reidy, Esq.
Attorneys for Defendants,
H. J. HEINZ COMPANY L.P., erroneously sued
as "H. J. Heinz Company" and HEINZSEED,
an unincorporated division of H.J. HEINZ
COMPANY, L.P.

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[PROPOSED] ORDER

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Appearing that good cause exists pursuant to the foregoing stipulation of the Parties, IT
IS HEREBY ORDERED that the deadlines for discovery and motions set forth in the Status
(Pretrial Scheduling) Order, are rescheduled as follows:
Deadline for:

Currently Scheduled
Deadline:

Proposed Rescheduled
Deadline

Non-Expert Discovery
Closes

September 30, 2014

November 14, 2014

Last Day to Disclose
Experts and Produce
Expert Reports

October 31, 2014

December 15, 2014

Last Day to Disclose
Rebuttal Experts and
Produce Expert Rebuttal
Reports

November 30, 2014

January 15, 2015

Expert Discovery Closes

December 31, 2014

February 13, 2015

Last Day to File Motions,
Except for
Continuances,
Temporary Restraining
Orders, or Other
Emergency Applications

December 31, 2014

February 13, 2015

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SO ORDERED.
Dated: July 18, 2014

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TAT TOHUMCULUK v. HEINZSEED

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Case No:2:13-CV-00773-WBS

STIPULATION AND ORDER TO CONTINUE DISCOVERY DEADLINES