Beaver v. Target Corporation

Filing 8

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 09/29/17 ORDERING that fact Discovery shall be completed by 06/15/18; Designation of Expert Witnesses due by 08/14/18 with any supplemental expert disclosures due 09/13/18. A Joint Notice of Trial Readiness is due no later than 30 days after receiving this Court's ruling(s) on the last filed dispositive motion(s). If the parties do not intend to file dispositive motions, the parties are ordered to file a Joint Notice of Trial Readiness no later than 30 days after the close of the designation of supplemental expert witnesses. (Benson, A.)

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1 2 3 4 5 6 7 8 L. JULIUS M. TURMAN (SBN 226126) jturman@constangy.com PHILIP J. SMITH (SBN 232462) psmith@constangy.com CONSTANGY BROOKS SMITH AND PROPHETE LLP 50 California Street, Suite 1625 San Francisco, California 94111 Telephone: (415) 918-3000 Facsimile: (415) 918-3007 Attorneys for Defendant TARGET CORPORATION 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 Plaintiff, 12 vs. 13 14 15 Case No. 17-cv-01254-MCE-CMK LORRI BEAVER, STIPULATION AND ORDER REGARDING DISCOVERY PLAN TARGET CORPORATION, AND DOES 1 THROUGH 50 Defendants. 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND ORDER REGARDING DISCOVERY -1- 17-CV-01254-MCE-CMK PLAN _ 1 The Parties to the above-captioned action, Defendant TARGET CORPORATION 2 (“Defendant”) and Plaintiff LORRI BEAVER (“Plaintiff”)(collectively, the “Parties”) by and 3 through their attorneys of record, hereby stipulate and agree to the following discovery 4 plan: 5 WHEREAS, pursuant to the Court’s Initial Pretrial Scheduling Order for this matter, 6 the Parties met and conferred pursuant to Rule 26 of the Federal Rules of Civil Procedure 7 to formulate a discovery plan; 8 WHEREAS, the parties agreed, pursuant to the terms of the Court’s Initial Pretrial 9 Scheduling Order, that fact discovery must be completed by June 15, 2018, which is within 10 one year of the date of removal; 11 WHEREAS, the parties agreed, pursuant to the terms of the Court’s Initial Pretrial 12 Scheduling Order, that the expert disclosure deadline shall be August 14, 2018, which is 13 within 60 days of the close of fact discovery; 14 WHEREAS, the parties stipulate, pursuant to the terms of the Court’s Initial Pretrial 15 Scheduling Order, that supplemental expert disclosure deadline shall be September 13, 16 2018, which is within 30 days of the initial expert designations; and 17 WHEREAS, the Parties have exchanged their initial disclosures; 18 THEREFORE, the parties stipulate that fact discovery must be completed by June 19 20 21 22 23 15, 2018; THEREFORE, the parties stipulate that the expert disclosure deadline shall be August 14, 2018; and THEREFORE, the parties stipulate that the supplemental expert disclosure deadline shall be September 13, 2018. 24 25 26 27 28 STIPULATION AND ORDER REGARDING DISCOVERY PLAN -2- 17-CV-01254-MCE-CMK 1 Dated: September 28, 2017 2 CONSTANGY, BROOKS, SMITH & PROPHETE LLP By /s/ L. Julius M. Turman L. Julius M. Turman Philip J. Smith Attorneys for Defendant TARGET CORPORATION By 3 /s/ T. James Fisher (as authorized on 9/19/17) T. James Fisher Attorneys for Plaintiff LORRI BEAVER 4 5 6 7 Dated: September 28, 2017 8 9 10 ORDER 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Pursuant to the parties’ stipulation and the Court’s Initial Pretrial Scheduling Order, ECF No. 3, fact discovery shall be completed by June 15, 2018; the deadline to disclose experts shall be August 14, 2018; and the supplemental expert disclosure deadline is September 13, 2018. As also provided in the Initial Pretrial Scheduling Order, the parties are ordered to file a Joint Notice of Trial Readiness not later than thirty (30) days after receiving this Court's ruling(s) on the last filed dispositive motion(s). If the parties do not intend to file dispositive motions, the parties are ordered to file a Joint Notice of Trial Readiness not later than thirty (30) days after the close of the designation of supplemental expert witnesses and the notice must include statements of intent to forgo the filing of dispositive motions. The parties are directed to review the Initial Pretrial Scheduling Order, ECF No. 3, for additional information. IT IS SO ORDERED. Dated: September 29, 2017 26 27 28 STIPULATION AND ORDER REGARDING DISCOVERY PLAN -3- 17-CV-01254-MCE-CMK

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