Tabrizi v. Platt et al

Filing 20

ORDER EXTENDING DISCOVERY DEADLINE re 19 Stipulation filed by Christopher Platt, Avis Rent A Car System, Inc.. Signed by Judge Maria-Elena James on 4/20/2010. (mejlc1, COURT STAFF) (Filed on 4/20/2010)

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ROBERT A. BRAGG, Bar No. 99366 EDWARD GARCIA, Bar No. 173487 BRAGG & KULUVA Embarcadero Center West 275 Battery Street, Suite 1100 San Francisco, CA 94111 [phone] [phone] Attorneys for Defendants, Christopher Platt and Avis Rent A Car System, LLC (erroneously sued herein as Avis Rent a Car System, Inc. and Avis, Inc.)

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA FATEMEH TABRIZI, Plaintiff, vs. CHRISTOPHER PLATT; AVIS RENT A CAR SYSTEM, INC; AVIS, INC.; DOES 1 TO 50, Defendants. CASE NO. 3:09-CV-04305-MEJ STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE MANAGEMENT (PRETRIAL SCHEDULING) ORDER

Plaintiff FATEMEH TABRIZI and Defendants Christopher Platt and Avis Rent A Car System, LLC, by and through their respective undersigned counsel, hereby enter into the following stipulation and request to modify the Case Management (Pretrial Scheduling) Order dated December 28, 2009, as follows: 1. WHEREAS, the December 28, 2009 Case Management (Pretrial Scheduling) Order

provides that expert witnesses with reports are to be disclosed by May 14, 2010, rebuttal experts are to be disclosed by May 24, 2010, and closure of discovery (including depositions of expert witnesses) by June 8, 2010. 2. WHEREAS, Plaintiff's deposition has been scheduled for May 18, 2010, for the

convenience of all counsel and the witness. 1
STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE MANAGEMENT (PRETRIAL SCHEDULING) ORDER

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3.

WHEREAS, the expert witnesses retained by the parties will need to review the

deposition transcript of the Plaintiff, among other documents, to prepare their respective reports. 4. WHEREAS, all parties seek to continue the dates for expert disclosure, rebuttal expert

disclosure, and closure of discovery date by approximately 45 days, so that Defendants can complete Plaintiff's deposition and then both parties provide said deposition transcript to their respective experts. 5. Therefore, the parties respectfully submit that good cause exists and request

modification of the scheduling order as follows: i. ii. iii. 6. Expert Disclosure: June 28, 2010

Rebuttal Expert Disclosure: July 8, 2010 Discovery Closure: July 26, 2010

All other provisions of the December 28, 2009 Case Management (Pretrial

Scheduling) Order remain in effect. IT IS HEREBY STIPULATED.

DATED: April 14, 2010

By: /s/_________________ EDWARD GARCIA Attorney for Defendants Platt and Avis Rent A Car System, LLC By: /s/____________________ DAVID C. ANDERSON Attorney for Plaintiff Fatemeh Tabrizi

DATED: April 14, 2010

PURSUANT TO STIPULATION, IT IS SO ORDERED.

April 20, 2010 DATED: _________________

______________________________ Maria-Elena James Chief United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE MANAGEMENT (PRETRIAL SCHEDULING) ORDER