Sahara Smoke Co. v. Kako et al

Filing 51

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/3/15. Discovery Completion Date: 6/19/15; Plaintiffs Expert Disclosures: 8/21/15; Defendants Expert Disclosures: 8/21/15; All remaining pretrial dates shall remain as set. (Manzer, C)

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Joel M. Weinstein
(SBN # 213016)
RANDOLPH LAW, PLLC
PO Box 50752
Arlington, VA 22205
Tel: [phone]
[e-mail]

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Christopher Shiplett pro hac vice
RANDOLPH LAW, PLLC
PO Box 50752
Arlington, VA 22205
Tel: [phone]
[e-mail]

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Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SAHARA SMOKE CO.,

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Plaintiff,

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CASE NO. 2:13-CV-02588-TLN-CKD

STIPULATION AND ORDER TO
EXTEND DISCOVERY DATES;
ORDER

v.
JOHN KAKO and
SAHARA HOOKAH LLC,

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Defendants.

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Plaintiff Sahara Smoke Co., and Defendants John Kako and Sahara Hookah LLC

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through their respective counsels, hereby submit the following stipulation and

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Order to extend discovery dates and request modification of the Court’s scheduling

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order pursuant to Rule 16 of the Federal Rules of Civil Procedure.
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Recitals

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1. On August 13, 2014, this Court’s Scheduling Order set the following

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dates for the completion of discovery, including expert discovery.

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Discovery Completion Date: March 19, 2015;
Plaintiff’s Expert Disclosures: May 21, 2015;
Defendant’s Expert Disclosures: May 21, 2015;

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2. The parties are working diligently and appear to be close to a settlement
on this matter.
3. The parties do not seek or wish to change any remaining dates, including
dates for dispositive motions, pretrial conference, or trial.
4. The parties previously submitted a stipulation to an extension of the
discovery period, which the court denied without prejudice, and with
leave to re-file provided that the re-filed stipulation ensured that the
pretrial dates were amended in compliance with the court’s pretrial
scheduling order to afford the court adequate time between applicable

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deadlines.
5. The parties have modified the previous stipulation and proposed order to
remove the proposed separate deadline to file discovery motions, which

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would have had discovery motions heard after the deadline for

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dispositive motions and after the final pretrial conference, and would

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have conflicted with the scheduling order’s mandate to have all discovery

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disputes resolved by order prior to the discovery deadline.

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Stipulation
Accordingly, based upon the foregoing, the parties hereby STIPULATE that:

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6. The deadline for completion of all discovery shall be continued to June
19, 2015.
7. The date for Plaintiff to make his disclosure of experts under Rule

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26(a)(2) shall be continued to August 21, 2015.
8. The date for Defendants to make their disclosure of experts under Rule
26(a)(2) shall be continued to August 21, 2015.
9. All remaining pretrial dates shall remain as set by the Court in its August
13, 2014 Order.

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IT IS SO STIPULATED.

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Dated February 2, 2015.

RANDOLPH LAW, PLLC
BY: /s/ Joel M. Weinstein
Joel M. Weinstein
Attorney for Sahara Smoke Co.

Dated February 2, 2015.

DAVIS & LEONARD, LLP
BY: /s/ Stephen L. Davis (SBN. 149817)
STEPHEN L. DAVIS
Attorney for Defendants John Kako and
Sahara Hookah LLC

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ORDER

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Having read and considered the parties’ Stipulation to Extend Discovery Dates IT

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IS HEREBY ORDERED THAT:

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The dates for completion of discovery, including expert discovery, shall be
CONTINUED to the dates set forth in the stipulation above; and

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All remaining pretrial dates set by this Court’s August 13, 2014 Scheduling
Order shall remain UNCHANGED.

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The extension of the deadlines relating to discovery ordered above SHALL NOT
BE CONSIDERED IN DERTIMINING WHETHER THERE IS GOOD CAUSE

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FOR THE EXTENSION OF ANY OTHER DEADLINES set in this Court’s

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August 13, 2014 Scheduling Order.

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IT IS SO ORDERED.
Dated: February 3, 2015

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Troy L. Nunley
United States District Judge

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