Vazquez et al v. Target Corporation et al

Filing 21

STIPULATION and ORDER signed by District Judge John A. Mendez on 10/8/2019 MODIFYING the Court's Scheduling Order as follows: Expert Witness Disclosure due by 6/5/2020, with supplemental disclosure and disclosure of any rebuttal experts due by 7 /3/2020, Discovery to be completed by 8/21/2020, Dispositive Motions filed by 9/29/2020, to be heard on 10/27/2020 at 1:30 PM, Final Pretrial Conference set for 12/11/2020 at 11:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez, Joint Pretrial Statement due by 12/4/2020, Jury Trial set for 1/11/2021 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Huang, H)

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1 2 3 4 5 Michael R. Mordaunt, Esq., Bar No. 66911 Lori A. Reihl, Esq., Bar No. 246395 RIGGIO MORDAUNT & KELLY 2509 West March Lane, Suite 200 Stockton, CA 95207 Telephone: (209) 473-8732 Attorneys for Defendants TARGET CORPORATION 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 VANESSA VAZQUEZ and SAMUEL VAZQUEZ Case No. 2:17-cv-01106-JAM-AC STIPULATION FOR EXTENSION OF DEADLINES AND ORDER Plaintiff(s), 12 13 vs. 14 TARGET CORPORATION, MATTHEW WATSON and DOES 1 through 10, inclusive, 15 16 Defendant(s). 17 18 In this action plaintiff Vanessa Vazquez, alleges ongoing complaints and continuing 19 treatment for back pain that she contends is related to the slip and fall incident at issue in this 20 action. Plaintiff previously received a left sacroiliac joint injection in November 2018, which 21 initially provided relief. However, she just recently returned in July 2019 reporting a return of her 22 back pain. Since this visit was just recently completed, records are still being obtained. According 23 to plaintiff, since she responded so well to injections for her left low back, her treating physician 24 has recommended the same treatment for her right side. That injection was just recently completed. 25 The outcome of this additional injection will not be known for several months until it can be 26 evaluated whether any relief persists or whether her pain complaints return. Based on this recent 27 treatment, the parties stipulate and agree that an extension of the current discovery deadlines is 28 warranted. With the current deadlines, the parties have insufficient time to obtain complete 1 STIPULATION FOR EXTENSION OF DEADLINES AND [PROPOSED] ORDER 1 medical records on this scheduled treatment, evaluate the outcome of the recent injection, and 2 complete meaningful expert disclosures and discovery. 3 THEREFORE, it is hereby stipulated and agreed that the court’s Scheduling Order relative 4 to this matter shall be modified as follows: 5 6 7 8 9 10 11 12 13 14 15 16 1. The deadline for expert witness disclosures under Fed. R. Civ. P. 26(a)(2) shall be extended from August 16, 2019 to June 5, 2020. 2. The deadline for supplemental disclosure and disclosure of any rebuttal experts under Fed. R. Civ. P. 26(a)(2)(c) shall be extended from September 17, 2019 to July 3, 2020. 3. The deadline to complete all discovery shall be extended from October 11, 2019 to August 21, 2020. 4. The deadline for all dispositive motions shall be extended from November 8, 2019 to June 5, 2020. The hearing on such motions shall be July 17, 2020 at 1:30pm. 5. The final pre-trial conference shall be continued from January 31, 2020 at 11:00am to August 28, 2020 at 11:00am. The joint pre-trial statement is now due August 21, 2020. 6. The jury trial in this matter shall be re-set from March 9, 2020 at 9:00am to October 5, 2020 at 9:00am. 17 18 Dated: 10/2/19 DRYER BABICH BUCCOLA WOOD CAMPORA 19 By: /s/ Christopher Wood, Esq. Christopher Wood, Esq. Larry Phan, Esq. Attorneys for Plaintiffs VANESSA VAZQUEZ and SAMUEL VAZQUEZ 20 21 22 23 24 Dated: 10/1/19 RIGGIO MORDAUNT & KELLY 25 By: /s/ Lori A. Reihl, Esq. Michael R. Mordaunt, Esq. Lori A. Reihl, Esq. Attorneys for Defendant TARGET CORPORATION 26 27 28 2 STIPULATION FOR EXTENSION OF DEADLINES AND [PROPOSED] ORDER ORDER (AS MODIFIED BY THE COURT) 1 2 Good cause having been shown, 3 IT IS HEREBY ORDERED that the parties to this matter that the court’s Scheduling Order 4 5 relative to this matter is modified as follows: 1. The deadline for expert witness disclosures under Fed. R. Civ. P. 26(a)(2) shall be June 5, 2020. 6 7 2. The deadline for supplemental disclosure and disclosure of any rebuttal experts under Fed. R. Civ. P. 26(a)(2)(c) shall be July 3, 2020. 8 9 10 3. The deadline to complete all discovery shall be August 21, 2020. 4. The deadline for all dispositive motions shall be September 29, 2020. The hearing on such motions shall be October 27, 2020 at 1:30pm. 11 12 5. The final pre-trial conference shall be December 11, 2020 at 11:00am. The joint pretrial statement is now due December 4, 2020. 13 14 6. The jury trial in this matter shall be January 11, 2021 at 9:00am. 15 16 DATED: 17 October 8, 2019 /s/ John A. Mendez__________________ United States District Court Judge 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION FOR EXTENSION OF DEADLINES AND [PROPOSED] ORDER

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