Mobile Hi-Tech Wheels v. TWM Wholesale, LLC et al

Filing 41

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 3/28/2019 EXTENDING discovery dates as follows: Fact discovery to be completed by 5/30/2019; Designation of experts due 6/30/2019; Supplemental list of expert witnesses due 7/30/2019; Joint Notice of Trial Readiness (if the parties do not intend to file dispositive motions) due 8/30/2019; Dispositive motions deadline 8/30/2019. (Zignago, K.)

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THOMAS J. DALY, CA Bar No. 119684
[e-mail]
DREW WILSON, CA Bar No. 283616
[e-mail]
LEWIS ROCA ROTHGERBER CHRISTIE LLP
655 N. Central Avenue, Suite 2300
Glendale, CA 91203-1445
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
MOBILE HI-TECH WHEELS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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655 North Central Avenue
Suite 2300
Glendale, CA 91203-1445

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MOBILE HI-TECH WHEELS,
Plaintiff,
vs.

Case No. 2:18-cv-00339-MCE (GGHx)`
STIPULATED REQUEST TO EXTEND
DISCOVERY DEADLINES; ORDER
THEREON

TWM WHOLESALE, LLC and
TIRE & WHEEL MASTER, INC.;
TIRE & WHEEL MASTER, LLC;
USA WHEEL & TIRE OUTLET, INC.;
Hon. Morrison C. England, Jr.
ASLAM PROPERTY, INC.;
HB COMMERCIAL, LLC; NADEEM ASLAM;
and AMMAD HUSSAIN,
Defendants.

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Plaintiff Mobile Hi-Tech Wheels (“MHT”) and Defendants TWM Wholesale, LLC,

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Tire & Wheel Master Inc., Tire & Wheel Master LLC, USA Wheel & Tire Outlet Inc.,

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USA Wheel & Tire Outlet, Inc., Aslam Property, Inc., HB Commercial, LLC, Nadeem

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Aslam, and Ammad Hussain (collectively, “Defendants”), by and through their

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respective counsel, hereby jointly request that the Court extend the discovery deadline

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to permit discovery to be completed by all Parties.

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-1STIPULATED REQUEST TO EXTEND DISCOVERY DATES; ORDER THEREON

107584956_2

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In support of this stipulated request, the Parties submit the following:

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1.

The deadline for fact discovery to be completed was February 12, 2019.

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2.

The Parties have been working in good faith to complete discovery in a

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timely manner.

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3.

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scheduling conflicts.

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The Parties have not completed all discovery due to continuing

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The Parties have pending cross motions for summary judgment that

have the potential to simplify discovery and narrow the scope of the case.

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655 North Central Avenue
Suite 2300
Glendale, CA 91203-1445

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WHEREFORE, the Parties respectfully request that the Court extend the
discovery deadlines as follows:

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1.

2019.

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2.

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The deadline for the designation of experts be extended to June 30,

3.

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The deadline for fact discovery to be completed be extended to May 30,

The deadline for supplemental list of expert witnesses be extended to

2019.

July 30, 2019.
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The deadline to submit the Joint Notice of Trial Readiness (if the parties

do not intend to file dispositive motions) be extended to August 30, 2019.
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The deadline for dispositive motions to be extended to August 30, 2019.

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IT IS SO STIPULATED.

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-2STIPULATED REQUEST TO EXTEND DISCOVERY DATES; ORDER THEREON

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Dated: March 20, 2019

Respectfully submitted,
LEWIS ROCA ROTHGERBER
CHRISTIE LLP

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By

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/s/Thomas J. Daly
Thomas J. Daly
Drew Wilson
Attorneys for Plaintiff
MOBILE HI-TECH WHEELS

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Dated: March 20, 2019

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By

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655 North Central Avenue
Suite 2300
Glendale, CA 91203-1445

BRADFORD, LTD.
/s/Aaron P. Bradford
Aaron P. Bradford
(as authorized on 3/20/2019)
Attorneys for Defendants
TWM WHOLESALE, LLC and
TIRE & WHEEL MASTER, INC.;
TIRE & WHEEL MASTER, LLC;
USA WHEEL & TIRE OUTLET, INC.;
ASLAM PROPERTY, INC.;
HB COMMERCIAL, LLC; NADEEM
ASLAM; and AMMAD HUSSAIN

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IT IS SO ORDERED.
Dated: March 28, 2019

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-3STIPULATED REQUEST TO EXTEND DISCOVERY DATES; ORDER THEREON

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