Palumbo v. W. Atlee Burpee & Co.

Filing 15

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr., on 11/19/14 ORDERING that the new expert disclosure deadline is 1/23/15, and the new rebuttal expert disclosure deadline is 2/20/15. (Kastilahn, A)

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EDWARD GARCIA, Bar No. 173487
BRAGG & KULUVA
Embarcadero Center West
275 Battery Street, Suite 1100
San Francisco, CA 94111
[phone]
[phone]
[e-mail]
Attorneys for Defendant,
W. Atlee Burpee Company
(erroneously sued as “W. Atlee Burpee & Co.”)

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Lawrance A. Bohm (SBN: 208716)
[e-mail]
Victoria L. Baiza (SBN: 282715)
[e-mail]
BOHM LAW GROUP
4600 Northgate Boulevard, Suite 210
Sacramento, CA 95834
Telephone: [phone]
Facsimile: 916.927.2046
Attorneys for Plaintiff,
TRACY PALUMBO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT

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TRACY A. PALUMBO

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Plaintiff,

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JOINT STIPULATION RE: EXTENSION
OF EXPERT DISCLOSURE
DEADLINES; [PROPOSED ORDER]

vs.

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CASE NO. 2:13-CV-02057-GEB-DAD

W. ATLEE BURPEE & CO.; AND DOES 150, INCLUSIVE,
Defendants.

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THE PARTIES, THROUGH THEIR RESPECTIVE COUNSEL, STIPULATE TO THE
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FOLLOWING:
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JOINT STIPULATION RE: EXTENSION OF EXPERT DISCLOSURE DEADLINES; [PROPOSED] ORDER

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1. Whereas, the Court’s scheduling order in this matter sets the expert disclosure deadline on
October 20, 2014;
2. Whereas, the Court’s scheduling order in this matter sets the rebuttal expert disclosure
deadline on November 24, 2014;

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3. Whereas the parties previously stipulated to extend the expert disclosure deadline to

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December 12, 2014, and rebuttal expert disclosure deadlines to January 16, 2015;

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4. Whereas, the deposition of Defendant employee Mike Walker by Plaintiff is currently

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scheduled for December 2, 2014;
5. Whereas the parties have scheduled a settlement conference with a Magistrate Judge
Kendall J. Newman for January 16, 2015;
6. Therefore, the parties agree to further extend the expert disclosure deadline to January
23, 2015, and rebuttal expert disclosure deadlines to February 20, 2015.
DATED: November 13, 2014

BRAGG & KULUVA

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By: /s/__________________________
EDWARD GARCIA
Attorney for Defendant
W. Atlee Burpee Company

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DATED: November 13, 2014

BOHM LAW GROUP

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By: /s/ Victoria L. Baiza_____
(as authorized on 11/19/14)
VICTORIA L. BAIZA
Attorney for Plaintiff
Tracy A. Palumbo

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[PROPOSED] ORDER
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Pursuant to stipulation, IT IS SO ORDERED that the new expert disclosure deadline is

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January 23, 2015, and the new rebuttal expert disclosure deadline is February 20, 2015.

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Dated: November 19, 2014

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JOINT STIPULATION RE: EXTENSION OF EXPERT DISCLOSURE DEADLINES; [PROPOSED] ORDER