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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1 2 3 4 5 6 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: (209) 473-8732 Attorneys for Defendant TARGET CORPORATION 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 SHERON R. WRIGHT, Plaintiff(s), 12 13 14 vs. TARGET CORPORATION, Defendant(s). 15 ) Case No. 2:16-CV-01193-JAM-CKD ) ) STIPULATION TO EXTEND DEADLINES ) AND [PROPOSED] ORDER ) ) ) ) ) ) WHEREAS the parties previously entered into a stipulation, and an order was entered by 16 17 this court on August 16, 2017, to continue the dates concerning disclosure of expert witnesses. The 18 deadline for mutual disclosure of expert witnesses and exchange of expert reports is now October 19 20, 2017, and the mutual disclosure of rebuttal expert witnesses and exchange of reports deadline is 20 November 17, 2017. 21 However, by that stipulation and order, the parties inadvertently did not extend discovery 22 23 of September 15, 2017. Therefore, an extension of time on all case deadlines and dates is necessary 24 to allow time for time for the completion of expert disclosures and discovery, including expert 25 depositions, prior to the close of discovery and in sufficient time prior to trial and motion deadlines. 26 Based on the foregoing: 27 Riggio Mordaunt & Kelly 2509 W March Lane Suite 200 Stockton, CA 95207 (209) 473-8732 deadlines, leaving the parties with a date for expert disclosures after the current discovery deadline /// 28 /// 1 STIPULATION TO EXTEND EXPERT DISCLOSURE DEADLINES, AND [PROPOSED] ORDER 1 IT IS HEREBY STIPULATED AND AGREED that: 2 1. The current discovery cut-off date of September 15, 2017 shall be extended to 3 4 January 19, 2018. 2. The current dispositive motion deadline of November 7, 2017 shall be extended to 5 March 16, 2018 and heard on April 17, 2018 at 1:30pm. 6 IN ADDITION, the parties request that: 7 1. The Final Pretrial Conference currently scheduled for January 12, 2018 be continued to 8 9 10 May 18, 2018. 2. The jury trial currently scheduled to commence on February 26, 2018 be continued to June 25, 2018. 11 12 13 Dated: September 11, 2017 14 AMERIO LAW FIRM By: 15 16 /s/ ASHLEY AMERIO Ashley Amerio, Esq. Jeffrey Fletterick, Esq. Attorney for Plaintiff SHERON R. WRIGHT 17 18 Dated: September 12, 2017 RIGGIO MORDAUNT & KELLY 19 20 By: 21 /s/ LORI A. REIHL Lori A. Reihl, Esq. Attorneys for Defendant TARGET CORPORATION 22 23 24 25 26 27 Riggio Mordaunt & Kelly 2509 W March Lane Suite 200 Stockton, CA 95207 (209) 473-8732 28 2 STIPULATION TO EXTEND EXPERT DISCLOSURE DEADLINES, AND [PROPOSED] ORDER ORDER (AS MODIFIED BY THE COURT) 1 2 Good cause having been shown, 3 4 5 6 7 8 9 10 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. 11 12 DATED: September 12, 2017 /s/ John A. Mendez_________________ Judge of the United States District Court 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Riggio Mordaunt & Kelly 2509 W March Lane Suite 200 Stockton, CA 95207 (209) 473-8732 28 3 STIPULATION TO EXTEND EXPERT DISCLOSURE DEADLINES, AND [PROPOSED] ORDER

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