Urps et al v. Skaggs et al

Filing 25

STIPULATION AND ORDER signed by District Judge Vince Chhabria on 4/14/2017 ORDERING Mediation Cutoff due by 6/30/2017; Fact Discovery Cutoff by 8/21/2017; Initial Expert Disclosure and related expert dates will be 7/31/2017; the new Rebuttal Expert Disclosure will be 8/21/2017; and the new Close of Expert Discovery will be 9/18/2017. (Reader, L)

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ERIC J. RATINOFF / SBN: 166204
MARLA C. STRAIN / SBN: 132142
ERIC RATINOFF LAW CORP.
401 Watt Avenue
Sacramento, CA 95864
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JENNIFER URPS, an individual,
JAMES URPS, an individual, and
JOSHUA URPS, an individual

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THE HONORABLE VINCE CHHABRIA

Plaintiffs,

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Case No.: 2:16-CV-02185-VC

v.

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STIPULATION AND [PROPOSED
ORDER] TO EXTEND MEDIATION
CUT-OFF AND MODIFY TRIAL
MANAGEMENT SCHEDULE

JOHN CURTIS SKAGGS, an individual,
RIVERSIDE TRANSPORT INC., a
Delaware corporation; PENSKE TRUCK
LEASING CORPORATION, a Delaware
corporation; and DOES 1 through 15,
inclusive,
Defendants.

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Case Removed: September 14, 2016

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IT IS HEREBY STIPULATED by the parties, through their attorneys of record, as follows:

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WHEREAS, pursuant to the Court’s December 6, 2016 Order After Hearing on Initial Case

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Management Conference, Document 2, jury trial is scheduled for November 13, 2017. The parties

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do not seek a continuance of the November 13, 2017 trial date.

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WHEREAS, pursuant to the Court’s December 6, 2016 Order, Document 2, the deadline to
complete mediation is May 1, 2017.

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WHEREAS, pursuant to the Court’s December 6, 2016 Order, Document 2, the fact

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discovery cut-off is June 22, 2017.

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///
-1STIPULATION TO EXTEND MEDIATION CUT-OFF AND MODIFY TRIAL MANAGEMENT CHEDULE
2:16-CV-02185-VC

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WHEREAS, pursuant to the Court’s December 6, 2016 Order, Document 2, the deadline

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for initial expert disclosures is May 31, 2017; the deadline for disclosure of rebuttal experts is June

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21, 2017; and the deadline for closure of expert discovery is July 18, 2017.

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WHEREAS, the parties have agreed to mediate this matter with Hon. Cecily Bond (Ret.).

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WHEREAS, the parties agree that a sixty (60) day continuance of the May 1, 2017

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mediation cut off will result in a more meaningful mediation. The parties further agree that a sixty

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(60) day continuance of the June 22, 2017 fact discovery cut off and the May 31, 2017 deadline for

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initial expert disclosures (and related expert deadlines), will benefit all parties and increase the

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chance mediation with Judge Bond will resolve the pending litigation.

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IT IS HEREBY STIPULATED that:
1. Mediation cutoff be continued for sixty (60) days. The new mediation cutoff will be June 30,
2017.
2. Fact discovery cutoff be continued for sixty (60) days. The new fact discovery cutoff will by
August 21, 2017.

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3. Initial Expert Disclosure, and related expert dates, be continued for sixty (60) days. The new

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Initial Expert Disclosure will be July 31, 2017; the new Rebuttal Expert Disclosure will be

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August 21, 2017; the new Close of Expert Discovery will be September 18, 2017.

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Dated: April 10, 2017

ERIC RATINOFF LAW CORP.

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By:

/s/ MARLA C. STRAIN
MARLA C. STRAIN
ERIC RATINOFF
401 Watt Avenue
Sacramento, CA 95864
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs

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-2STIPULATION TO EXTEND MEDIATION CUT-OFF AND MODIFY TRIAL MANAGEMENT CHEDULE
2:16-CV-02185-VC

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Dated: April 10, 2017

SELMAN BREITMAN LLP

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By:

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/s/ BRADFORD G. HUGHES (with permission)
BRADFORD G. HUGHES
11766 Wilshire Blvd., Sixth Floor
Los Angeles, CA 90025
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants

IT IS SO ORDERED.

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April 14, 2017
Dated: _______________________

________________________________________
UNITED STATES DISTRICT JUDGE

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-3STIPULATION TO EXTEND MEDIATION CUT-OFF AND MODIFY TRIAL MANAGEMENT CHEDULE
2:16-CV-02185-VC