Television Education, Inc. v. Contractors Intelligence School, Inc. et al

Filing 35

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 02/13/2017 ORDERING that the Status (Pretrial Scheduling) Order is MODIFIED so that the deadline to disclose experts and produce reports in accordance with FRCP 26(a) (2) shall be EXTENDED to 5/1/2017; the deadline to disclose rebuttal experts and produce reports shall be EXTENDED to 5/30/2017; and the deadline to complete expert discovery only shall be EXTENDED to 6/30/2017. (Jackson, T)

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BOUTIN JONES INC.
Michael E. Chase (SBN 214506)
[e-mail]
Bashar S. Ahmad (SBN 258619)
[e-mail]
555 Capitol Mall, Suite 1500
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
Television Education, Inc.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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TELEVISION EDUCATION, INC.

)
)
Plaintiff,
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vs.
)
)
CONTRACTORS INTELLIGENCE SCHOOL, )
INC.; CONTRACTORS PUBLISHER, INC.;
)
LEONID VORONTSOV; OKSANA
)
VORONTSOV; and DOES 1-25,
)
)
Defendants.
)

Case No. 2:16-cv-01433-WBS-EFB
STIPULATION AND [PROPOSED]
ORDER TO MODIFY STATUS
(PRETRIAL SCHEDULING) ORDER TO
EXTEND TIME TO COMPLETE EXPERT
DISCOVERY

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Plaintiff Television Education, Inc. (“Television Education”) and Defendants Contractors

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Intelligence School, Inc.; Contractors Publisher, Inc.; Leonid Vorontsov and Oksana Vorontsov

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(“Defendants”), by and through their undersigned counsel of record, hereby stipulate as follows

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and propose that the Court enter an order consistent with this Stipulation.

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WHEREAS, pursuant to the Status (Pretrial Scheduling) Order filed October 19, 2016, the

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deadline for parties to disclose experts and produce reports in accordance with Federal Rule of

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Civil Procedure 26(a)(2) is March 31, 2017; the deadline to disclose rebuttal experts and produce

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reports is April 28, 2017; and the deadline to complete discovery is May 31, 2017; and

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WHEREAS, Plaintiff and Defendants have been diligently engaged in factual and
percipient witness discovery; and
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STIPULATION AND [PROPOSED] ORDER TO MODIFY STATUS (PRETRIAL SCHEDULING) ORDER TO
EXTEND TIME TO COMPLETE EXPERT DISCOVERY
850034.1

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WHEREAS, despite their diligence, and due to the schedules of witnesses and counsel, the

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parties do not anticipate they will be able to complete factual and percipient witness discovery and

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depositions in time to comply with the March 31 deadline to disclose experts; and

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WHEREAS, the parties have not requested any prior modification of the Status (Pretrial
Scheduling) Order; and

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WHEREAS, Plaintiff and Defendants agree and stipulate that parties should have an
additional 30 days within which to complete expert discovery;

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IT IS HEREBY STIPULATED AND AGREED that good cause exists for this Court to

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enter an Order modifying the Status (Pretrial Scheduling) Order so that the deadline to disclose

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experts shall be extended to May 1, 2017; the deadline to disclose rebuttal experts shall be

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extended to May 30, 2017; and the deadline to complete expert discovery only shall be extended to

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June 30, 2017.

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SO STIPULATED:

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DATED: February 10, 2017

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BOUTIN JONES INC.
By:

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/s/MICHAEL E. CHASE
MICHAEL E. CHASE
BASHAR AHMAD

Attorneys for Plaintiff Television Education, Inc.

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DATED: February 10, 2017

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TINGLEY LAW GROUP, PC
By:

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/s/ STEPHEN D. COLLINS (W/ PERMISSION)
STEPHEN D. COLLINS

Attorneys Defendants Contractors Intelligence
School, Inc.; Contractors Publisher, Inc.; Leonid
Vorontsov and Oksana Vorontsov

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STIPULATION AND [PROPOSED] ORDER TO MODIFY STATUS (PRETRIAL SCHEDULING) ORDER TO
EXTEND TIME TO COMPLETE EXPERT DISCOVERY
850034.1

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ORDER MODIFYING STATUS (PRETRIAL SCHEDULING) ORDER TO EXTEND TIME

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TO COMPLETE EXPERT DISCOVERY

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Upon the stipulation of Plaintiff Television Education, Inc. and Defendants Contractors

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Intelligence School, Inc.; Contractors Publisher, Inc.; Leonid Vorontsov and Oksana Vorontsov, by

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and through their respective counsel, and good cause appearing,

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IT IS ORDERED that the Status (Pretrial Scheduling) Order is modified so that the

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deadline to disclose experts and produce reports in accordance with Federal Rule of Civil

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Procedure 26(a)(2) shall be extended to May 1, 2017; the deadline to disclose rebuttal experts and

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produce reports shall be extended to May 30, 2017; and the deadline to complete expert discovery

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only shall be extended to June 30, 2017.

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IT IS SO ORDERED

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Dated: February 13, 2017

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STIPULATION AND [PROPOSED] ORDER TO MODIFY STATUS (PRETRIAL SCHEDULING) ORDER TO
EXTEND TIME TO COMPLETE EXPERT DISCOVERY
850034.1