Wright v. Target Corporation

Filing 15

STIPULATION AND ORDER signed by District Judge John A. Mendez on 8/16/2017 ORDERING all parties to disclose expert witnesses and exchange expert reports by 10/20/2017; ORDERING all parties to disclose rebuttal expert witnesses and exchange reports by 11/17/2017. (Michel, G.)

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Michael R. Mordaunt, Esq., Bar No. 66911
Lori A. Reihl, Esq., Bar No. 246395
RIGGIO MORDAUNT & KELLY
A Professional Law Corporation
2509 West March Lane, Suite 200
Stockton, CA 95207
Telephone: [phone]
Attorneys for Defendant
TARGET CORPORATION

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EASTERN DISTRICT OF CALIFORNIA OF CALIFORNIA, COUNTY OF UNITED STATES
DISTRICT COURT

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SHERON R. WRIGHT,
Plaintiff(s),

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vs.
TARGET CORPORATION,
Defendant(s).

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) Case No. 2:16-CV-01193-JAM-CKD
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) STIPULATION TO EXTEND EXPERT
) DISCLOSURE DEADLINES, AND ORDER
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WHEREAS the parties agree that a continuance of the dates concerning disclosure of expert
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witnesses is in their mutual interest.
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The parties have agreed to engage in mediation with Eric Emanuels, Esq. in Sacramento,
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California. Based on the availability of the mediator and all parties involved, mediation is
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scheduled for September 20, 2017. It is the parties’ intent to engage in early mediation prior to the
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parties engaging in the time and cost of further discovery, expert disclosures and expert discovery,
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to promote settlement discussions.
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An extension of time for expert disclosures is necessary to allow time for the completion of
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mediation on September 20, 2017. Additionally, should mediation not be successful, the
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depositions of plaintiff’s treating physicians will need to be completed, which are necessary for
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retained expert witnesses to provide a complete report for expert disclosures. Based on the
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foregoing:
Riggio Mordaunt & Kelly
2509 W March Lane
Suite 200
Stockton, CA 95207
[phone]

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STIPULATION TO EXTEND EXPERT DISCLOSURE DEADLINES, AND [PROPOSED] ORDER

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IT IS HEREBY STIPULATED AND AGREED that mutual disclosure of expert witnesses

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and exchange of expert reports shall take place on or before October 20, 2017, and the mutual

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disclosure of rebuttal expert witnesses and exchange of reports shall take place on or before

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November 17, 2017. All other dates in the court’s Scheduling Order shall remain in effect.

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Dated: August 16, 2017

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AMERIO LAW FIRM
By:

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/S/ JEFFREY FLETTERICK, ESQ.
Jeffrey Fletterick, Esq.
Attorney for Plaintiff
SHERON R. WRIGHT

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Dated: August 16, 2017

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RIGGIO MORDAUNT & KELLY
By:

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/S/ LORI A. REIHL, ESQ.
Lori A. Reihl, Esq.
Attorneys for Defendant
TARGET CORPORATION

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ORDER

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Good cause having been shown,
IT IS HEREBY ORDERED that the parties to this matter that the court’s Scheduling Order

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of expert reports shall take place on or before October 20, 2017, and the mutual disclosure of

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rebuttal expert witnesses and exchange of reports shall take place on or before November 17, 2017.

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DATED: August 16, 2017

/s/ John A. Mendez__________________
Judge of the United States District Court

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Riggio Mordaunt & Kelly
2509 W March Lane
Suite 200
Stockton, CA 95207
[phone]

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STIPULATION TO EXTEND EXPERT DISCLOSURE DEADLINES, AND [PROPOSED] ORDER