Tabrizi v. Platt et al

Filing 30

ORDER CONTINUING DISCOVERY DEADLINE re 29 Stipulation filed by Christopher Platt, Avis Rent A Car System, Inc.. Signed by Judge Maria-Elena James on 8/26/2010. (mejlc1, COURT STAFF) (Filed on 8/26/2010)

Tabrizi v. Platt et al

Doc. 30

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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] [e-mail] 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 CONTINUE DISCOVERY CLOSURE

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: 1. WHEREAS Chief United States Magistrate Judge Maria-Elena James issued a Case Management (Pretrial Scheduling) Order in this matter on December 28, 2009, which included dates for expert disclosure, rebuttal expert disclosure, and closure of discovery date. 2. WHEREAS the parties previously submitted a Stipulation and Order to Modify Case Management (Pretrial Scheduling) Order, and this Court signed the Order on July 16, 2010; and the modified Case Management (Pretrial Scheduling) Order provides, in part, closure of discovery 1
STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY CLOSURE

Dockets.Justia.com

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(including depositions of expert witnesses) by July 26, 2010. 4. WHEREAS the parties have completed disclosure of experts. 5. WHEREAS the parties need additional time to schedule and complete the depositions of each sides retained and non-retained experts. 6. WHEREAS all parties seek to continue the date for the closure of discovery by approximately 45 additional days so that the parties can complete expert depositions. 7. Therefore, the parties respectfully submit that good cause exists and request

modification of the scheduling order as follows: i. Discovery Closure: October 29, 2010

IT IS HEREBY STIPULATED.

DATED: August 25, 2010

By: /s/ Edward Garcia______ EDWARD GARCIA Attorney for Defendants Platt and Avis Rent A Car System, LLC

DATED: August 25, 2010

By: /s/ David C. Anderson________ DAVID C. ANDERSON Attorney for Plaintiff Fatemeh Tabrizi

PURSUANT TO STIPULATION, IT IS SO ORDERED.

August 26, 2010 DATED: _________________

______________________________ Maria-Elena James Chief United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY CLOSURE