Vazquez et al v. Target Corporation et al

Filing 14

STIPULATION and ORDER signed by District Judge John A. Mendez on 4/12/2018 MODIFYING the Court's Scheduling Order: Dispositive motions filed by 2/19/2019; Motion Hearing set for 3/19/2019 at 1:30PM in Courtroom 6 (JAM) before District Judge John A. Mendez; Discovery to be completed by 12/21/2018; Expert witness disclosures made by 10/19/2018 with any supplemental/rebuttal expert disclosures made by 11/13/2018; Final pre-trial conference RESET for 4/26/2019 at 10:00AM in Courtroom 6 (JAM) before District Judge John A. Mendez; Jury trial RESET for 6/10/2019 at 9:00AM in Courtroom 6 (JAM) before District Judge John A. Mendez.(Fabillaran, J)

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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
Post Office Box 7608 (Zip Code 95267)
2509 West March Lane, Suite 200
Stockton, CA 95207
Telephone: [phone]
Attorneys for Defendants
TARGET CORPORATION

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IN THE UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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VANESSA VAZQUEZ and SAMUEL
VAZQUEZ

Case No. 2:17-cv-01106-JAM-AC
STIPULATION FOR EXTENSION OF
DEADLINES AND ORDER

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Plaintiff(s),
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vs.
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TARGET CORPORATION,
MATTHEW WATSON and DOES 1
through 10, inclusive,

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Defendant(s).
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The parties have been attempting to coordinate and complete the depositions of plaintiffs

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and witnesses, but have been unable to complete the depositions due to multiple scheduling

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conflicts, including the unavailability of plaintiff’s counsel due to multiple trials.

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These depositions of plaintiffs are now being coordinated for May 2018. Once the

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depositions are completed and additional medical records are obtained, the parties will need an

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opportunity to consider the issues and retain those experts necessary to respond to the damage

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issues resulting from the outcome of this information. Plaintiffs’ deposition testimony, as well as

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updated medical information is necessary for retained expert witnesses to provide a complete report

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for expert disclosures and to complete an independent medical evaluation of the plaintiff.

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The current scheduling order deadlines do not allow sufficient time for the parties to

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complete the remaining discovery necessary following these depositions, adequately prepare expert
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STIPULATION FOR EXTENSION OF DEADLINES AND [PROPOSED] ORDER

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disclosures, and prepare for trial.
THEREFORE, it is hereby stipulated and agreed that the court’s Scheduling Order relative
to this matter shall be modified as follows:
1. All dispositive motions shall be filed by February 21, 2019. The hearing on such
motions shall be on March 29, 2019 at 1:30pm.

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2. All discovery shall be completed by December 21, 2018.

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3. The parties shall make expert witness disclosures under Fed. R. Civ. P. 26(a)(2) by

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October 19, 2018. Supplemental disclosure and disclosure of any rebuttal experts under

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Fed. R. Civ. P. 26(a)(2)(c) shall be made by November 13, 2018.

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4. The final pre-trial conference shall be continued to April 26, 2019 at 10:00am

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5. The jury trial in this matter shall be continued to June 10, 2019 at 9:00am

12 Dated: April 12, 2018

DRYER BABICH BUCCOLA WOOD
CAMPORA

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By:
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/s/ Christopher Wood
Christopher Wood, Esq.
Attorneys for Plaintiffs
VANESSA VAZQUEZ and SAMUEL
VAZQUEZ

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Dated: April 12, 2018

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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STIPULATION FOR EXTENSION OF DEADLINES AND [PROPOSED] ORDER

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ORDER (AS MODIFIED BY THE COURT)

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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
relative to this matter is modified as follows:
1. All dispositive motions shall be filed by February 19, 2019. The hearing on such
motions shall be on March 19, 2019 at 1:30pm.
2. All discovery shall be completed by December 21, 2018.
3. The parties shall make expert witness disclosures under Fed. R. Civ. P. 26(a)(2) by
October 19, 2018. Supplemental disclosure and disclosure of any rebuttal experts under
Fed. R. Civ. P. 26(a)(2)(c) shall be made by November 13, 2018.
4. The final pre-trial conference shall be continued to April 26, 2019 at 10:00am
5. The jury trial in this matter shall be continued to June 10, 2019 at 9:00am.

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DATED: 4/12/2018

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

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STIPULATION FOR EXTENSION OF DEADLINES AND [PROPOSED] ORDER