Edwards v. Princess Cruise Lines, Ltd.

Filing 98

STIPULATION AND ORDER. Signed by Magistrate Judge Bernard Zimmerman on 12/1/2010. (bzsec, COURT STAFF) (Filed on 12/1/2010)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 158 HILLTOP CFRESCENT WALNUT CREEK, CA 94597 (925) 588-0401 TIMOTHY S. THIMESCH, Esq. (No. 148213) 158 Hilltop Crescent Walnut Creek, CA 94597-3452 Direct: (925) 588-0401 Facsimile: (888) 210-8868 Email: tim@thimeschlaw.com Attorneys for Plaintiff KATHLEEN EDWARDS KAYE, ROSE & PARTNERS, LLP BRADLEY M. ROSE, ESQ. (126281) AKSANA MOSHAIV, ESQ. (190125) 1801 Century Park East, Suite 1500 Los Angeles, California 90067 Telephone: (310) 277-1200 2 Facsimile: (310) 277-1220 Email: brose@kayerose.com Email: amoshaiv@kayerose.com RONALD K. LOSCH, ESQ. KAYE, ROSE & PARTNERS, LLP 425 California Street, Suite 2025 San Francisco, CA 94104 Telephone No.: 415-433-6555 Facsimile No.: 415-433-6577 Email: rlosch@kayerose.com Attorneys for Defendant PRINCESS CRUISE LINES, LTD. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA KATHLEEN EDWARDS, Plaintiff, v. PRINCESS CRUISE LINES, LTD., and DOES 1 through 15, Inclusive, Defendants. / TO THE COURT: Recently, and at the joint request of the parties, the Stipulation to Enlarge Scheduling Order Dates: Case No. C05-03076-BZ CASE NO. C05-03076-BZ Civil Rights SECOND STIPULATION AND PROPOSED ORDER TO ENLARGE SCHEDULING ORDER DATES AND DISCOVERY RESTRICTIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 158 HILLTOP CRESCENT WALNUT CREEK, CA 94597 (925) 588-0401 Court continued the trial and Scheduling Order deadlines by 60 days to accommodate a November 5, 2010 Settlement Conference that was scheduled before Magistrate Judge Laporte. recently, and due to the unexpected availability However, of the Magistrate Judge, the parties were advised that the Conference need to be continued to January 7, and, even more recently, they advised again that the conference needs to be continued to an as of yet undetermined date. Therefore, the parties request another approximate 90-day continuance of trial and scheduling order dates to accommodate the rescheduling of the Settlement Conference, and to provide the parties space to balance ongoing discovery efforts with the effort to reach stipulations of fact and reduction of issues for trial. The parties will utilize their best efforts to resolve the matter at the Settlement Conference. At the very least, the conference should significantly reduce the claims and issues required for trial. Therefore, the parties seek the following new deadlines: Non-Expert Discovery Close: Expert Disclosure Due: Last Day for Rebuttal Expert Disclosures: Expert Discovery Deadline: Last Day to Hear Dispositive Motions: Final Pretrial Conference: Last Day to Meet and Confer Jury Trial: //// Stipulation to Enlarge Scheduling Order Dates: Case No. C05-03076-BZ March 15, 2011 March 22, 2011 March 29, 2011 April 5, 2011 4 May 16, 2011 July 22, 2011 at 4PM August 3, 2011 at 9AM 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 158 HILLTOP CRESCENT WALNUT CREEK, CA 94597 (925) 588-0401 SO STIPULATED. Dated: November 30, 2010 TIMOTHY S. THIMESCH Attorneys for Plaintiff KATHLEEN EDWARDS Dated: November 30, 2010 KAYE, ROSE & PARTNERS, LLP BRADLEY M. ROSE, ESQ. AKSANA MOSHAIV, ESQ. RONALD K. LOSCH, ESQ. KAYE, ROSE & PARTNERS, LLP By: /s/ SIGNATURE AUTHORIZED Attorneys for Defendant PRINCESS CRUISE LINES, LTD. ORDER IT IS SO ORDERED. Status conference to follow dispositive motion hearing and set new trial date if necessary. . Date: December 1, 2010 HON. BERNARD ZIMMERMAN MAGISTRATE JUDGE U.S. District Court Stipulation to Enlarge Scheduling Order Dates: Case No. C05-03076-BZ 3

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