Tyurina v. Urbana Tahoe TC LLC et al

Filing 33

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 12/1/17, ORDERING that the designation of expert witnesses deadline is EXTENDED to 1/31/2018, and the deadline to designate supplemental expert witnesses is due 20 days thereafter. The close of non-expert discovery is EXTENDED to 12/29/2017. (Kastilahn, A)

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James W. Rushford, Esq. (SBN 088739)
RUSHFORD & BONOTTO, LLP
1010 Hurley Way, Suite 410
Sacramento, California 95825
Phone: [phone]
Fax: [phone]
[e-mail]
R. Gregory Amundson, Esq. (SBN 079710)
Edward D. Baldwin, Esq. (SBN 160723)
WOOD, SMITH, HENNING & BERMAN, LLP
5000 Birch Street, Ste. 8500
Newport Beach, CA 92660
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants/Cross-Defendants/Counter-Claimants
URBANA TAHOE TC LLC and
URBANA TAHOE BEVERAGE COMPANY, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ELENA TYURINA,
Plaintiff,
vs.
URBANA TAHOE TC LLC; URBANA
TAHOE BEVERAGE COMPANY, LLC
dba Beach Retreat and Lodge
Tahoe,
Defendants.

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AND RELATED CROSS-CLAIMS

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Case No.: 2:16-cv-00759-TLN-DB
STIPULATION AND ORDER TO
EXTEND THE CLOSE OF NONEXPERT DISCOVERY AND TO
EXTEND THE EXPERT
DISCLOSURE CUTOFF DATE
COMPLAINT FILED: 04/13/16
TRIAL DATE: 07/16/18

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Subject to the approval of this Court, the parties hereby stipulate to

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extend the deadline for the disclosure of expert witnesses from December

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STIPULATION AND ORDER TO EXTEND THE CLOSE OF NON-EXPERT DISCOVERY AND TO EXTEND THE EXPERT
DISCLOSURE CUTOFF DATE

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11, 2017 to January 31, 2018, with the deadline to designate supplemental

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expert witnesses to be set twenty (20) days thereafter.
The parties further stipulate to extend the close of non-expert

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discovery from November 30, 2017 to December 29, 2017.

The parties

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have previously requested one additional extension for the discovery cutoff

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and for the expert disclosure deadline.
This case has involved multiple depositions in various locations

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throughout the country.

The parties have been diligently pursuing such

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discovery. There remain some additional fact witnesses to be deposed in

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addition to plaintiff’s treating health care providers in Minnesota. Despite

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their diligence, the parties are still in the midst of completing fact

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discovery.

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discovery cutoff and to postpone the expert disclosure deadline to allow

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time to process evidence expected from the continued fact discovery

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before confirming their selection of experts and submitting their expert

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reports.

The parties accordingly wish to postpone the non-expert

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The parties do not request any change or extension of any other

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previously established dates in the Court’s Scheduling Order of August 29,

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2016.

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Trial in this matter is set for July 16, 2018 and thus an amended

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expert disclosure deadline would still comport with the requirement that

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expert disclosures be made 90 days before trial.

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26(a)(2)(D). The parties do not request any change or extension of any

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other previously established dates in the Court’s Scheduling Order of

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August 29, 2016.
SO STIPULATED.

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Fed. R. Civ. P.

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STIPULATION AND ORDER TO EXTEND THE CLOSE OF NON-EXPERT DISCOVERY AND TO EXTEND THE EXPERT
DISCLOSURE CUTOFF DATE

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Dated: November 14, 2018

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RUSHFORD & BONOTTO, LLP
By: /s/ James W. Rushford
JAMES W. RUSHFORD
Attorneys for Defendants, URBANA
TAHOE TC LLC and URBANA TAHOE
BEVERAGE COMPANY, LLC dba Beach
Retreat and Lodge Tahoe

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Dated: November 14, 2018

WOOD SMITH HENNING & BERMAN,
LLP

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By: /s/ Robert G. Amundson
ROBERT G. AMUNDSON (SBN 79710)
Attorneys for Defendants, URBANA
TAHOE TC LLC and URBANA TAHOE
BEVERAGE COMPANY, LLC dba Beach
Retreat and Lodge Tahoe

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Dated: November 14, 2018

WALKUP, MELODIA, KELLY &
SCHOENBERGER

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By: /s/ Valerie N. Rose
MICHAEL A. KELLY (SBN 71460)
VALERIE N. ROSE (SBN 272566)
Attorneys for Plaintiff, ELENA TYURINA

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Dated: November 14, 2018

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By: /s/ Roger A. Dreyer
ROGER A. DREYER (SBN 95462)
Attorneys for Plaintiff, ELENA TYURINA

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DREYER BABICH BUCCOLA WOOD
CAMPORA, LLP

Dated: November 14, 2018

PAGLIERO & ASSOCIATES

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STIPULATION AND ORDER TO EXTEND THE CLOSE OF NON-EXPERT DISCOVERY AND TO EXTEND THE EXPERT
DISCLOSURE CUTOFF DATE

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By: /s/ James R. Pagliero
JAMES R. PAGLIERO (SBN 95898)
Attorneys for Defendant, ACTION
MOTORSPORTS OF TAHOE, INC.

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PURSUANT TO THE ABOVE STIPULATION, IT IS SO ORDERED.

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Dated:

12/01/2017

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Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER TO EXTEND THE CLOSE OF NON-EXPERT DISCOVERY AND TO EXTEND THE EXPERT
DISCLOSURE CUTOFF DATE