Haddad v. Hilton Worldwide Holdings, Inc. et al

Filing 21

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr., on 2/27/17 ORDERING that discovery shall be conducted so as to be completed by 8/23/2017. (Kastilahn, A)

1 Stephen C. Ruehmann,; SBN 167533
Christine N. Weil, Esq.; SBN 298418
2 BORTON PETRINI, LLP
Post Office Box 277790
3 Sacramento, California 95827
3110 Gold Canal Drive, Suite A
4 Rancho Cordova, California 95670
Tel: [phone]
5 Fax: [phone]
Email: [e-mail]
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Attorneys for Defendants Hilton Worldwide Holdings, Inc.; Hilton
7 Worldwide, Inc.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FADI HADDAD,

Case No. 2:16-CV-00405-MCE-CKD
Plaintiff,

v.

STIPULATION TO EXTEND DISCOVERY
CUTOFF DATE; PROPOSED ORDER

HILTON WORLDWIDE HOLDINGS, INC.;
15 HILTON WORLDWIDE, INC.; and DOES 1-50
Inclusive,
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Defendants.
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The parties are informed and believed that the current discovery cutoff date is February 23, 2017.

19 However, both parties agree for good cause to be shown that this deadline will not allow them to
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complete all necessary discovery and have stipulated to moving the deadline to August 23, 2017. All
other deadlines, including expert discovery, shall follow the Initial Pretrial Scheduling Order from the
Court. No prior requests to extend this discovery deadline have been made and this matter has yet to be

24 set for trial.
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This case involves a personal injury that is alleged to have occurred at the Hilton Abu Dhabi in
the United Arab Emirates. Defendants contend that due to the various locations of key evidence and key
witnesses, discovery and investigation is taking longer than anticipated. Corporate defendants, although
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STIPULATION TO EXTEND DISCOVERY CUTOFF DATE

2:16-CV-00405-MCE-CKD

1 located in the United States, must coordinate and communicate with another entity in Abu Dhabi to
2 investigate the claims as well as respond to plaintiff’s discovery along with other entities related to the
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Hilton Abu Dhabi which are likewise located abroad. Furthermore, plaintiff initially obtained healthcare
for the subject injury in the United Arab Emirates and in Lebanon and to obtain those records will

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require coordination with outside counsel to assist in obtaining those records. Subpoenas may need to be
served pursuant to the provisions of the Hague Convention. The process is expected to take several

8 months. Finally, a key eye witness, the masseuse who is alleged to have injured plaintiff, has not been
9 located by defendants. The masseuse is no longer employed by Hilton Abu Dhabi and is believed to be
10 living in Qatar. It is anticipated by defendants that she is likely to be a key witness for defense purposes.
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The parties are cooperating with regard to taking foreign and/or out of state depositions. The
parties have agreed to make all party witnesses and third party witnesses (within their control) available

14 for depositions via videoconference and/or teleconference without foreign or out of state deposition
15 commissions, to the extent possible, to save the time and expense of foreign travel.
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The parties also wish to engage in meaningful mediation prior to the beginning of expert

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discovery. The parties are not prepared to mediate this matter based on the current discovery deadline.

19 DATED: February

, 2017

BORTON PETRINI, LLP

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ENGSTROM, LIPSCOMB & LAC

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, 2017

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By
/s/ Stephen C. Ruehmann_________
Stephen C. Ruehmann, Attorneys for
Defendants Hilton Worldwide Holdings, Inc.;
Hilton Worldwide, Inc.
ENGSTROM, LIPSCOMB & LACK
By

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/s/ Steven J. Lipscomb
Steven J. Lipscomb, Attorneys for
Plaintiff Fadi Haddad

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STIPULATION TO EXTEND DISCOVERY CUTOFF DATE

2:16-CV-00405-MCE-CKD

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Good cause appearing, discovery shall be conducted so as to be completed by August 23, 2017.
IT IS SO ORDERED.

5 Dated: February 27, 2017
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STIPULATION TO EXTEND DISCOVERY CUTOFF DATE

2:16-CV-00405-MCE-CKD