Emerton v. Clean Harbors, Inc.

Filing 30

STIPULATION AND ORDER signed by District Judge Troy L. Nunley on 11/3/2015 MODIFYING the 15 Pretrial Scheduling Order; ORDERING that discovery be completed by 2/13/2016; ORDERING that disclosure of expert witness information be completed by 4/3/2016. (Michel, G.)

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DAVID YEREMIAN & ASSOCIATES, INC.
David H. Yeremian (SBN 226337)
[e-mail]
Michele Jackson (SBN 209841)
[e-mail]
535 North Brand Boulevard, Suite 705
Glendale, California 91436
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff LAURA EMERTON

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Sarah R. Nichols, CA Bar No. 233099
[e-mail]
Victoria L. Tallman, CA Bar No. 273252
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
SteuartTower, Suite 1300
One MarketPlaza
San Francisco, CA94105
Telephone:
415.442.4810
Facsimile:
415.442.4870

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Attorneys for Defendants
CLEAN HARBORS INDUSTRIAL SERVICES, INC.;
And CLEAN HARBORS, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LAURA EMERTON,
Plaintiff,

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Case No. 2:14-cv-02658-TLN-DAD

vs.

STIPULATION AND ORDER SEEKING TO
MODIFY PRE-TRIAL SCHEDULING
ORDER

CLEAN HARBORS, INC., A CALIFORNIA
CORPORATION; AND DOES 1 THROUGH
50, INCLUSIVE,
Action Filed:
Trial Date:
Defendants.

October 3, 2014
October 3, 2016

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Plaintiff Laura Emerton (“Plaintiff”) and Defendants Clean Harbors Industrial Services,

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Inc. and Clean Harbors, Inc. (collectively “Defendants”), by and through their undersigned

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counsel, hereby stipulate as follows:
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Case No.2:14-cv-02658-TLN-DAD
STIPULATION AND ORDER SEEKING TO MODIFY PRE-TRIAL SCHEDULING ORDER

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STIPULATION

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A.

Order in this matter dated March 25, 2015;

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B.

C.

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WHEREAS, the March 25, 2015 Pre-Trial Scheduling Order calls for the disclosure

of expert witnesses to occur on January 7, 2016;

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WHEREAS, the March 25, 2015 Pre-Trial Scheduling Order calls for discovery to

close on November 5, 2015;

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WHEREAS, the Honorable Judge Troy L. Nunley issued a Pre-Trial Scheduling

D.

WHEREAS, although they have acted with due diligence, neither party has

completed discovery and in the interest of promoting meaningful litigation through discovery, the
parties seek to amend the March 25, 2015 Pre-Trial Scheduling Order to allow discovery to
continue until February 13, 2016 and to exchange expert witness information on or before April 3,
2016;
IT IS HEREBY STIPULATED:
1. The Parties wish to amend the Pre-Trial Scheduling Order to permit discovery to
continue until a Discovery Close date of February 13, 2016.
2. The Parties wish to amend the Pre-Trial Scheduling Order with regard to Disclosure
of Expert Witnesses to occur on or before April 3, 2016.
3. All other dates in the March 25, 2015 Pre-Trial Scheduling Order are to remain
unchanged.

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DATED: November 3, 2015

DAVID YEREMIAN & ASSOCIATES, INC.

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By /s/Michele Jackson
David Yeremian
Michele L. Jackson
Attorneys for Plaintiff
LAURA EMERTON

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Case No.2:14-cv-02658-TLN-DAD
STIPULATION AND ORDER SEEKING TO MODIFY PRE-TRIAL SCHEDULING ORDER

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DATED: November 3, 2015

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By:

/s/Victoria L. Tallman
Sarah R. Nichols
Victoria L. Tallman
Attorneys for Defendant
CLEAN HARBORS INDUSTRIAL
SERVICES, INC. and CLEAN HARBORS,
INC.

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Case No.2:14-cv-02658-TLN-DAD
STIPULATION AND ORDER SEEKING TO MODIFY PRE-TRIAL SCHEDULING ORDER

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ORDER
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The Court having reviewed the foregoing Stipulation, and good cause appearing therefore:
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IT IS HEREBY ORDERED that the March 25, 2015 Pre-Trial Scheduling Order be
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modified to reflect that Discovery in this matter shall be completed on February 13, 2016 and that
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Disclosure of Expert Witness Information shall occur on or before April 3, 2016. All other dates
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and information in the March 25, 2015 Pre-Trial Scheduling Order shall remain unchanged.
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IT IS SO ORDERED.
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Dated: November 3, 2015

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Troy L. Nunley
United States District Judge

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Case No.2:14-cv-02658-TLN-DAD
STIPULATION AND ORDER SEEKING TO MODIFY PRE-TRIAL SCHEDULING ORDER