Wright v. Target Corporation

Filing 17

STIPULATION and ORDER TO EXTEND DEADLINES signed by District Judge John A. Mendez on 9/12/17 ORDERING that Discovery shall be completed by 1/19/2018. All Dispositive Motions shall be filed by 3/27/2018 and heard on 4/24/18 at 1:30 p.m. The Final Pretrial Conference is SET for 6/1/2018 at 10:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. Jury Trial is SET for 7/9/2018 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Mena-Sanchez, L)

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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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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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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 DEADLINES
) AND [PROPOSED] ORDER
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WHEREAS the parties previously entered into a stipulation, and an order was entered by

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this court on August 16, 2017, to continue the dates concerning disclosure of expert witnesses. The

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deadline for mutual disclosure of expert witnesses and exchange of expert reports is now October

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20, 2017, and the mutual disclosure of rebuttal expert witnesses and exchange of reports deadline is

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November 17, 2017.

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However, by that stipulation and order, the parties inadvertently did not extend discovery

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of September 15, 2017. Therefore, an extension of time on all case deadlines and dates is necessary

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to allow time for time for the completion of expert disclosures and discovery, including expert

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depositions, prior to the close of discovery and in sufficient time prior to trial and motion deadlines.

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Based on the foregoing:

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

deadlines, leaving the parties with a date for expert disclosures after the current discovery deadline

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

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IT IS HEREBY STIPULATED AND AGREED that:

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1. The current discovery cut-off date of September 15, 2017 shall be extended to

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January 19, 2018.
2. The current dispositive motion deadline of November 7, 2017 shall be extended to

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March 16, 2018 and heard on April 17, 2018 at 1:30pm.

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IN ADDITION, the parties request that:

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1. The Final Pretrial Conference currently scheduled for January 12, 2018 be continued to

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May 18, 2018.
2. The jury trial currently scheduled to commence on February 26, 2018 be continued to
June 25, 2018.

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Dated: September 11, 2017

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AMERIO LAW FIRM
By:

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/s/ ASHLEY AMERIO
Ashley Amerio, Esq.
Jeffrey Fletterick, Esq.
Attorney for Plaintiff
SHERON R. WRIGHT

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Dated: September 12, 2017

RIGGIO MORDAUNT & KELLY

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By:

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

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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

ORDER (AS MODIFIED BY THE COURT)

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Good cause having been shown,

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IT IS HEREBY ORDERED that the parties to this matter that the court’s Scheduling Order
relative to this matter is modified as follows:
1. Discovery shall be completed by January 19, 2018.
2. All dispositive motions shall be filed by March 27, 2018 and heard on
April 24, 2018 at 1:30pm.
3. The Final Pretrial Conference is set for June 1, 2018 at 10:00AM in Courtroom 6.
4. Jury Trial is set for July 9, 2018 at 9:00am in Courtroom 6.

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DATED: September 12, 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