Bruce v. Experian Information Solutions, Inc.

Filing 14

STIPULATION and ORDER signed by District Judge John A. Mendez on 8/20/18. The deadline for supplemental expert witness disclosure and disclosure of rebuttal expert witness is CONTINUED to 8/31/2018. (Mena-Sanchez, L.)

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Thanh-Thuy T. Luong (State Bar No. 293859)
[e-mail]
JONES DAY
3161 Michelson Drive
Suite 800
Irvine, CA 92612.4408
Telephone: [phone]
Facsimile: +1.949.553.7539
Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS, 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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RABECCA BRUCE,

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Plaintiff,
v.
EXPERIAN INFORMATION
SOLUTIONS, INC.,
Defendant.

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Case No. 2:17-cv-01541-JAM-CMK
Hon. Magistrate Judge
Craig M. Kellison
STIPULATION TO CONTINUE
DEADLINE FOR
SUPPLEMENTAL EXPERT
WITNESS DISCLOSURE AND
DISCLOSURE OF REBUTTAL
EXPERT WITNESSES
Complaint filed: July 25, 2017

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Plaintiff Rabecca Bruce (“Plaintiff”) and Defendant Experian Information

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Solutions, Inc. (“Experian”) (collectively, “the Parties”), pursuant to Local Rule

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144, hereby stipulate to continue the deadline for supplemental expert witness

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disclosure and disclosure of rebuttal witnesses by two weeks, to August 31, 2018.

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The current deadline for supplemental expert witness disclosure and

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disclosure of rebuttal experts is August 17, 2018. The Parties have been actively

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working to resolve this case. The Parties would like the opportunity to exhaust

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settlement discussions prior to incurring the costs and expense of proceeding with

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further expert discovery.
STIPULATION TO EXTEND EXPERT REBUTTAL
AND SUPPLEMENTAL DISCLOSURES
Case No. 2:17-cv-01541-JAM-CMK

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Accordingly, the Parties respectfully request that the Court continue the

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deadline for supplemental expert witness disclosure and disclosure of rebuttal

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witnesses by two weeks to August 31, 2018. There have been no prior requests for

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extension of the deadlines set in the Status Order. The requested extension will not

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alter the date of any event or deadline fixed by the Status Order.

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Respectfully submitted,
Dated: August 17, 2018

JONES DAY

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By: /s/ Thanh-Thuy T. Luong
Thanh-Thuy T. Luong

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Attorneys for Defendant
EXPERIAN INFORMATION
SOLUTIONS, INC.

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Dated: August 17, 2018

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By: /s/ Stephanie R. Tatar (as
authorized on 8/17/2018)
Stephanie R. Tatar

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Attorney for Plaintiff

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IT IS SO ORDERED.
Dated: 8/20/2018 _______ _____

/s/ John A. Mendez________________
Hon. John A. Mendez
UNITED STATES DISTRICT JUDGE

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STIPULATION TO EXTEND EXPERT REBUTTAL
AND SUPPLEMENTAL DISCLOSURES
Case No. 2:17-cv-01541-JAM-CMK

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CERTIFICATE OF SERVICE

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I, Thanh-Thuy T. Luong, declare:

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I am a citizen of the United States and employed in Orange County,

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California. I am over the age of eighteen years and not a party to the within-entitled

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action. My business address is 3161 Michelson Drive, Suite 800, Irvine, California

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92612.4408. On August 17, 2018, I served a copy of the STIPULATION TO

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CONTINUE DEADLINE FOR SUPPLEMENTAL EXPERT WITNESS

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DISCLOSURE AND DISCLOSURE OF REBUTTAL EXPERT WITNESSES

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by electronic transmission.

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I am familiar with the United States District Court for the Eastern District of

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California’s practice for collecting and processing electronic filings. Under that

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practice, documents are electronically filed with the court. The court’s CM/ECF

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system will generate a Notice of Electronic Filing (NEF) to the filing party, the

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assigned judge, and any registered users in the case. The NEF will constitute

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service of the document. Registration as a CM/ECF user constitutes consent to

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electronic service through the court’s transmission facilities. Under said practice,

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the following CM/ECF users were served:

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Stephanie R. Tatar
Tatar Law Firm, APC
3500 West Olive Avenue, Suite 300
Burbank, CA 91505
T: [phone]
F: [phone]
Email: [e-mail]
Attorneys for Plaintiff

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Executed on August 17, 2018, at Irvine, California.

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/s/ Thanh-Thuy T. Luong
Thanh-Thuy T. Luong

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STIPULATION TO EXTEND EXPERT REBUTTAL
AND SUPPLEMENTAL DISCLOSURES
Case No. 2:17-cv-01541-JAM-CMK