Haddad v. Hilton Worldwide Holdings, Inc. et al
Filing
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STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 8/28/17: Discovery shall be conducted so as to be completed not later than October 22, 2017. (Kaminski, H)
LEWIS BRISBOIS BISGAARD & SMITH LLP
1 DANA ALDEN FOX, SB# 119761
Dana.Fox@lewisbrisbois.com
2 EDWARD E. WARD, JR., SB# 249006
Edward.Ward@lewisbrisbois.com
3 TERA A. LUTZ, SB# 305304
Tera.Lutz@lewisbrisbois.com
4 633 West 5th Street, Suite 4000
Los Angeles, California 90071
5 Telephone: 213.250.1800
Facsimile: 213.250.7900
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Attorneys for Defendants, HILTON
7 WORLDWIDE HOLDINGS, INC. and HILTON
WORLDWIDE, INC.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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12 FADI HADDAD,
CASE NO. 2:16-CV-00405-MCE-CKD
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The Hon. Morrison England, Jr.
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Plaintiff,
vs.
15 HILTON WORLDWIDE HOLDINGS, INC.;
HILTON WORLDWIDE, INC.; and DOES 116 50 Inclusive,
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STIPULATION RE DISCOVERY CUT
OFF DATE; ORDER
Trial Date:
None Set
Defendants.
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The parties are informed and believe that the current discovery cutoff date is August 23,
20 2017. However, both parties agree for good cause to be shown that this deadline will not allow
21 them to complete all necessary discovery and have stipulated to moving the deadline to October
22 22, 2017. All other deadlines shall follow the Initial Pretrial Scheduling Order from the Court with
23 the limited exception of certain expert discovery as referenced below.
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Defendants anticipate filing a motion to dismiss for improper venue or forum non
25 conviens. The parties hereby stipulate that disclosure of expert witnesses and submission of expert
26 reports shall occur thirty (30) days after the Court’s ruling on Defendants’ anticipated motion to
27 dismiss. However, in the event such motion is heard and ruled upon by the Court before
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4832-6180-5133.1
STIPULATION RE DISCOVERY CUT OFF DATE; ORDER
1 November 23, 2017, all expert discovery shall commence pursuant to the Court’s Initial Pretrial
2 Scheduling Order. One prior request to extend this discovery deadline has been made and this
3 matter has yet to be set for trial.
4
On July 18, 2017 Plaintiff served a Notice of Deposition of Wolfgang Meier; Notice of
5 Deposition of Person Most Knowledgeable at Hilton Worldwide Holdings, Inc.; and a Notice of
6 Deposition of Person Most Knowledgeable at Hilton Worldwide, Inc. All individuals are believed
7 to be located outside of the United States and Defendants must coordinate and communicate with
8 individuals in Abu Dhabi and Egypt to respond to this request. However, the parties have agreed
9 to cooperate with these requests and Defendants will produce person(s) most knowledgeable and
10 Mr. Meier for depositions to be initiated in the United States pursuant to videoconference and/or
11 telephonic conferences, in the event they have access to either telephonic or videoconference
12 capabilities. Further, Defendants contend that a key eye witness, the masseuse who is alleged to
13 have injured plaintiff, has not been located by Defendants. The masseuse is not employed with
14 Hilton Abu Dhabi and is believed to be living in Qatar.
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On August 1, 2017 Defendants served a Notice of Deposition of Plaintiff Fadi Haddad. On
16 August 17, 2017, plaintiff’s counsel informed counsel for defendants that plaintiff would be
17 unavailable for deposition.
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Both parties are working in good faith to produce their requested witnesses and do not
19 wish to pursue a motion to compel. Because both parties properly noticed depositions prior to the
20 discovery cutoff date and both parties intend to produce witnesses following the cutoff date, both
21 parties would be prejudiced by failure to extend the discovery cutoff date by sixty (60) days.
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STIPULATION RE DISCOVERY CUT OFF DATE; ORDER
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DATED: August _22__, 2017
LEWIS BRISBOIS BISGAARD & SMITH
LLP
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By:
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/s/ Tera A. Lutz
Dana Alden Fox
Edward E. Ward. Jr.
Tera A. Lutz
Attorneys for Defendants, HILTON
WORLDWIDE HOLDINGS, INC. and HILTON
WORLDWIDE, INC.
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8 DATED: August _22_, 2017
ENGSTROM, LIPSCOMB, & LACK
LLP
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By:
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/s/ Steven J. Lipscomb
Steven J. Lipscomb
Eric Bell
Attorneys for Plaintiff, FADI HADDAD
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ORDER
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Good cause appearing to amend the pretrial scheduling order, the Court orders that
discovery shall be conducted so as to be completed not later than October 22, 2017.
IT IS SO ORDERED.
Dated: August 28, 2017
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STIPULATION RE DISCOVERY CUT OFF DATE; ORDER
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