Sussex Financial Enterprises, Inc. v. Bayerische Hypo-Und Vereinsbank AG et al

Filing 158

STIPULATION AND ORDER Regarding Scheduling of Expert Disclosures and Depositions. Signed by Judge Samuel Conti on 1/21/10. (tdm, COURT STAFF) (Filed on 1/21/2010)

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Brady Law Group Steven J. Brady (SBN 116651) 1015 Irwin Street, Suite A San Rafael, CA 94901 Telephone: [phone] Facsimile: [phone] Richard L. Katz, Inc. Richard L. Katz (SBN 42902) P.O. Box 2310 Mill Valley, CA 94942-2310 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Sussex Financial Enterprises, Inc. Kasowitz, Benson, Torres & Friedman LLP Mark P. Ressler (admitted pro hac vice) Ronald R. Rossi (admitted pro hac vice) Seth Davis (admitted pro hac vice) 1633 Broadway New York, NY 10019 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants Bayerische Hypo- and Vereinsbank AG and HVB U.S. Finance, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SUSSEX FINANCIAL ENTERPRISES, INC, Plaintiff, JOINT STIPULATION AND [PROPOSED] ORDER RE SCHEDULING OF EXPERT DISCLOSURES AND DEPOSITIONS CASE NO. C-08-4791 SC

VS.

BAYERISCHE HYPO- UND VEREINSBANK AG, aka HYPOVEREINSBANK; et al., De f e nda nt s.

JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING EXPERT DISCOVERY

Case No. C-08-4791-SC

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Plaintiff Sussex Financial Enterprises, Inc. ("Sussex") and defendants Bayerische Hypound Vereinsbank AG and HVB U.S. Finance, Inc. (collectively "HVB"), by and through their respective counsel of record, hereby stipulate and agree as follows: WHEREAS on February 6, 2009, the Court issued a Minute Order in which the deadline for expert disclosures was set for January 31, 2010; WHEREAS on February 11, 2009, the Court issued a Status Conference Order, which was silent as to expert discovery; WHEREAS the parties believe it would be productive and in the interests of judicial economy and efficiency for the parties to obtain additional time to prepare expert disclosures; IT IS HEREBY STIPULATED, and the parties respectfully and in good faith request, that the Court orders as follows: 1. Expert disclosures shall be made by March 1, 2010. 2. Depositions of the parties' experts shall take place beginning no earlier than March 15, 2010 and must be completed by March 24, 2010, unless the parties mutually agree otherwise. 3. The stipulation shall not impact any other dates set forth by the Court in the Status Conference Order, dated February 11, 2009. Dated: January 19, 2010 Brady Law Group Steven J. Brady Richard L. Katz, Inc. Richard L. Katz

By: (3) AMA (, · Attorneys for Plaintiff Dated: January 19, 2010
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Kasowitz, Benson, Tones & Friedman LLP Mark P. Ressler Ronald R. Rossi Seth Davis

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JOINT STIPULATION AND [PROPOSED] ORDER CONCERNING EXPERT DISCOVERY

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Attorneys for Defendants
Case No. C-08-4791-SC

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