Ward v. Equilon Enterprises LLC et al

Filing 28

STIPULATION AND ORDER TO EXTEND DISCOVERY AND MEDIATION DEADLINES AND TO RESCHEDULE FURTHER CASE MANAGEMENT CONFERENCE. Further Case Management Conference set for 4/14/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco.Joint Case Management Conference Statement due 4/7/11. Signed by Judge Richard Seeborg on 10/8/10. (cl, COURT STAFF) (Filed on 10/8/2010)

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Ward v. Equilon Enterprises LLC et al Doc. 28 *E-Filed 10/8/10* 1 JOSEPH E. ADDIEGO III (CA State Bar No. 169522) NICK S. VERWOLF (admitted Pro Hac Vice) 2 DAVIS WRIGHT TREMAINE LLP 505 Montgomery Street, Suite 800 3 San Francisco, California 94111 Telephone: (415) 276-6500 (415) 276-6599 4 Facsimile: Email: joeaddiego@dwt.com nickverwolf@dwt.com 5 6 Attorneys for Defendants EQUILON ENTERPRISES LLC, and 7 SHELL OIL PRODUCTS COMPANY LLC 8 STEGER P. JOHNSON (CA State Bar No. 83421) JONES, CLIFFORD, JOHNSON, DEHNER, 9 WONG, MORRISON, SHEPPARD & BELL, LLP 100 Van Ness Avenue, 19th Floor 10 San Francisco, CA 94102 Telephone: (415) 431-5310 (415) 431-2266 11 Facsimile: Email: sjohnson@jonesclifford.com 12 Attorneys for Plaintiff, KENT WARD 13 14 15 16 17 KENT WARD, 18 19 20 21 22 23 24 Pursuant to Civil Local Rule 6-1(b) and 6-2 of the United States District Court for the IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) Plaintiff, ) ) v. ) ) EQUILON ENTERPRISES, LLC, SHELL OIL ) PRODUCTS COMPANY LLC AND DOES 1 ) TO 50, inclusive, ) ) Defendants. ) ) Case No. CV 09-04565 RS STIPULATION AND [PROPOSED ORDER] TO EXTEND DISCOVERY AND MEDIATION DEADLINES AND TO RESCHEDULE FURTHER CASE MANAGEMENT CONFERENCE [Civ. L.R. 6-1(b) 6-2] Trial Date: None DAVIS WRIGHT TREMAINE LLP 25 Northern District of California, it is hereby stipulated by and between Plaintiff Kent Ward and 26 Defendants Equilon Enterprises, LLC ("Equilon") and Shell Oil Products Company LLC 27 ("Shell"), by and through their respective counsel of record, as follows: 28 1 STIPULATION TO EXTEND DEADLINES AND CMC Case No. CV 09-04565 RS DWT 15683409v2 0050411-000105 Dockets.Justia.com 1 1) All discovery deadlines set forth in this Court's April 8, 2010 Case Management 2 Scheduling Order shall be continued by a period of 90 (ninety) days. 3 2) All expert discovery deadlines set forth in this Court's April 8, 2010 Case Management 4 Scheduling Order shall be continued by a period of 90 (ninety) days; 5 6 2) The current mediation deadline shall be extended by 90 days; and 3) The January 13, 2011 Further Case Management Conference shall be rescheduled for 7 April 14, 2011 at 10:00 a.m., or as soon thereafter as counsel may be heard, in the Courtroom of 8 the Honorable Richard Seeborg, Courtroom 3, 17th Floor, United States Courthouse, 450 Golden 9 Gate Avenue, San Francisco, California. The parties shall file a Joint Case Management 10 Statement on or before April 7, 2011. 11 DAVIS WRIGHT TREMAINE LLP The reason for this Stipulation is that the parties encountered difficulty scheduling 12 depositions, including those of key third party witnesses, and require additional time to locate 13 certain third party witnesses, and also to schedule and complete all necessary depositions. In 14 addition, at a deposition conducted on October 6, 2010, a dispute arose between the parties 15 concerning the application of the attorney-client privilege and attorney work product doctrine to 16 an investigation that was conducted after the subject incident, and additional time is required to 17 resolve this dispute by motion practice. 18 /// 19 20 21 22 23 24 25 26 27 28 2 STIPULATION TO EXTEND DEADLINES AND CMC Case No. CV 09-04565 RS DWT 15683409v2 0050411-000105 1 This is the first stipulated time modification in this case. No trial date has been set, so this 2 extension will not require that a trial date be rescheduled, but it will require that the Further Case 3 Management Conference currently set for January 13, 2011 be rescheduled. 4 IT IS SO STIPULATED. DAVIS WRIGHT TREMAINE LLP 6 7 8 9 10 11 By: /s/ JOSEPH E. ADDIEGO III 5 Date: October 8, 2010 Attorneys for Defendants EQUILON ENTERPRISES LLC, and SHELL OIL PRODUCTS COMPANY LLC DAVIS WRIGHT TREMAINE LLP 12 IT IS SO STIPULATED JONES, CLIFFORD, JOHNSON, DEHNER, WONG, MORRISON, SHEPPARD & BELL, LLP By: /s/ STEGER P. JOHNSON 13 Date: October 8, 2010 14 15 16 17 Attorneys for Plaintiff KENT WARD 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION TO EXTEND DEADLINES AND CMC Case No. CV 09-04565 RS DWT 15683409v2 0050411-000105 1 2 3 ORDER Pursuant to stipulation, the foregoing is approved and IT IS SO ORDERED. IT IS FURTHER ORDERED that the January 13, 2011 Further Case Management 4 Conference shall be rescheduled to April 14, 2011. The parties shall file a Joint Case Management 5 Statement on or before April 7, 2011. 6 8 7 DATED: October ___, 2010. 8 9 10 11 __________________________________________ THE HONORABLE RICHARD SEEBORG UNITED STATES DISTRICT COURT JUDGE DAVIS WRIGHT TREMAINE LLP 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ORDER Case No. CV 09-04565 RS DWT 15683409v2 0050411-000105

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