Englehart et al. v. St. Anton Building, LP et al.

Filing 38

STIPULATION and ORDER TO ALLOW IN EXCESS OF TEN (10) DEPOSITIONS signed by Magistrate Judge Allison Claire on 4/13/17. (Mena-Sanchez, L)

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Christopher F. Wohl, SBN: 170280
Alexandra M. Asterlin, SBN: 221286
PALMER KAZANJIAN WOHL HODSON LLP
2277 Fair Oaks Blvd., Suite 455
Sacramento, CA 95825
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants ST. ANTON BUILDING, LP, a
California limited partnership; ST. ANTON MULTIFAMILY
MANAGEMENT, INC.

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UNITED STATES DISTRICT COURT

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IN THE EASTERN DISTRICT OF CALIFORNIA

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JOHN KERR and KRYSTLE
ENGLEHART,

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Plaintiffs,

Case No. 2:16-cv-00414-WBS-AC
STIPULATION TO ALLOW IN EXCESS OF
TEN (10) DEPOSITIONS

v.
ST. ANTON BUILDING, LP, a
California limited partnership; ST.
ANTON MULTIFAMILY
MANAGEMENT, INC.; and DOES 1
through 25, inclusive,

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Defendants

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WHEREAS, as the parties have served initial disclosures and Plaintiffs have served
supplemental disclosures in this matter.

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WHEREAS, Plaintiffs have disclosed twenty-seven (27) witnesses in their disclosure and

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supplemental disclosure. Plaintiffs anticipate calling twenty-six (26) of these witnesses at the trial of

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this matter.

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WHEREAS, Defendants have disclosed a total of twelve (12) witnesses in their disclosure.
Defendants plan to call each of these witnesses at the trial of the matter.
WHEREAS, Defendants seek to depose each of the witnesses who Plaintiffs plan to have
testify at the trial of this matter.

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PALMER KAZANJIAN
WOHL HODSON LLP
2277 Fair Oaks Blvd., Suite 455
Sacramento, CA 95825
916.442.3552

STIPULATION TO ALLOW IN EXCESS OF TEN (10)
DEPOSITIONS

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WHEREAS, Plaintiffs seek to depose each of the witnesses who Defendants plan to have
testify at trial.

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WHEREAS, per FRCP Rule 30, the parties would be limited to ten (10) depositions per side.

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WHEREAS, the parties agree that each party shall be allowed to take in excess of ten (10)

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depositions in this matter. Specifically, the parties stipulate that Defendants may depose each of the

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witnesses named in Plaintiffs’ Rule 26 Disclosures and any supplement thereto, as well as the

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deposition of any expert witnesses disclosed by Plaintiffs. Similarly, the parties stipulate that

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Plaintiffs may depose each of the witnesses named in Defendants’ Rule 26 Disclosures and any

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supplement thereto, as well as the deposition of any expert witnesses disclosed by Defendants.

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IT IS SO STIPULATED.
Dated: April 13, 2017

PALMER KAZANJIAN WOHL HODSON LLP

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By: /s/ Christopher F. Wohl
Christopher F. Wohl
Attorneys for Defendants ST. ANTON
BUILDING, LP and ST. ANTON
MULTIFAMILY MANAGEMENT, INC.

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Dated: April 13, 2017

GAVRILOV & BROOKS

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By: /s/ Eliezer Cohen
Eliezer Cohen
Attorneys for Plaintiffs JOHN KERR and
KRYSTLE ENGLEHART

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ORDER

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Upon the agreement of the parties hereto, and Good Cause appearing

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IT IS SO ORDERED.

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DATED: April 13, 2017

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PALMER KAZANJIAN
WOHL HODSON LLP
2277 Fair Oaks Blvd., Suite 455
Sacramento, CA 95825
916.442.3552

STIPULATION TO MODIFY PRETRIAL SCHEDULING ORDER
AND DISCLOSURE OF EXPERT WITNESSES

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