Ward v. Equilon Enterprises LLC et al
Filing
52
STIPULATION AND ORDER RE 51 FOR THIRD EXTENSION OF DISCOVERY AND MEDIATION DEADLINES AND THE RESCHEDULE FURTHER CASE MANAGEMENT CONFERENCE. Further Case Management Conference set for 10/6/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 3/3/11. (cl, COURT STAFF) (Filed on 3/3/2011)
Ward v. Equilon Enterprises LLC et al
Doc. 52
*E-Filed 3/3/11* 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) STEVEN J. BELL (CA State Bar No. 126567) 9 JONES, CLIFFORD, JOHNSON, DEHNER, WONG, MORRISON, SHEPPARD & BELL, LLP 10 100 Van Ness Avenue, 19th Floor San Francisco, CA 94102 (415) 431-5310 11 Telephone: Facsimile: (415) 431-2266 sjohnson@jonesclifford.com 12 Email: 13 Attorneys for Plaintiff, KENT WARD 14 IN THE UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 SAN FRANCISCO DIVISION 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 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
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STIPULATION FOR THIRD EXTENSION OF DISCOVERY DEADLINES AND CMC Case No. CV 09-04565 RS DWT 16638856v1 0050411-000105
DAVIS WRIGHT TREMAINE LLP
) ) 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] FOR THIRD EXTENSION OF DISCOVERY AND MEDIATION DEADLINES AND TO RESCHEDULE FURTHER CASE MANAGEMENT CONFERENCE [Civ. L.R. 6-1(b) 6-2] Trial Date: None
Dockets.Justia.com
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1) All discovery and expert discovery deadlines set forth in this Court's April 8, 2010
2 Case Management Scheduling Order and originally extended for a period of 90 (ninety) days per 3 this Court's October 8, 2010 Stipulation and Order to Extend Discovery and Mediation Deadlines 4 and to Reschedule Further Case Management Conference, and extended another 45 (forty five) 5 days in this Court's January 20, 2011 Stipulation and Order For Second Extension of Discovery 6 and Mediation Deadlines and to Reschedule Further Case Management Conference, shall be 7 extended from the current deadlines stated in the January 20, 2011 Order, as follows: 8 9 a) b) On or before June 30, 2011, all non-expert discovery shall be completed; On or before July 29, 2011, plaintiff shall disclose expert testimony and
10 reports in accordance with Federal Rule of Civil Procedure 26(a)(2); 11
DAVIS WRIGHT TREMAINE LLP
c)
On or before August 31, 2011, defendants shall disclose expert testimony
12 and reports in accordance with Federal Rule of Civil Procedure 26(a)(2); 13 d) On or before September 30, 2011, all discovery of expert witnesses
14 pursuant to Federal Rule of Civil Procedure 26(b)(4) shall be completed. 15 16 2) The current mediation deadline shall be extended by 60 days. 3) The May 26, 2011 Further Case Management Conference shall be rescheduled for
17 October 6, 2011 at 10:00 a.m., or as soon thereafter as counsel may be heard, in the Courtroom of 18 the Honorable Richard Seeborg, Courtroom 3, 17th Floor, United States Courthouse, 450 Golden 19 Gate Avenue, San Francisco, California. The parties shall file a Joint Case Management 20 Statement on or before September 29, 2011. 21 The reason for this Stipulation is that counsel for Plaintiff recently had a tragic family
22 event occur that required his complete and immediate attention, such that he was not available to 23 participate in mediation and remaining discovery under the current schedule. Further, the first 24 available date for the parties and the mediator to conduct the mediation is not until the end of 25 April, 2011, and the parties desire to conduct the mediation before completing the remaining 26 depositions and discovery. 27 /// 28
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STIPULATION FOR THIRD EXTENSION OF DISCOVERY DEADLINES AND CMC Case No. CV 09-04565 RS DWT 16638856v1 0050411-000105
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This is the third stipulated time modification in this case, as set forth above. No trial date
2 has been set, so this extension will not require that a trial date be rescheduled, but it will require 3 that the Further Case Management Conference currently set for May 26, 2011 be rescheduled. 4 IT IS SO STIPULATED. DAVIS WRIGHT TREMAINE LLP 6 7 8 9 10 11 By: /s/ Joseph E. Addiego III JOSEPH E. ADDIEGO III
5 Date: March 3, 2011
Attorneys for Defendants EQUILON ENTERPRISES LLC, and SHELL OIL PRODUCTS COMPANY LLC
DAVIS WRIGHT TREMAINE LLP
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IT IS SO STIPULATED JONES, CLIFFORD, JOHNSON, DEHNER, WONG, MORRISON, SHEPPARD & BELL, LLP By: /s/ Steven J. Bell___ Steven J. Bell
13 Date: March 3, 2011 14 15 16 17 Attorneys for Plaintiff KENT WARD 18 19 20 21 22 23 24 25 26 27 28
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STIPULATION FOR THIRD EXTENSION OF DISCOVERY DEADLINES AND CMC Case No. CV 09-04565 RS DWT 16638856v1 0050411-000105
1 2 3
ORDER Pursuant to stipulation, the foregoing is approved and IT IS SO ORDERED. IT IS FURTHER ORDERED that the May 26, 2011 Further Case Management
4 Conference shall be rescheduled to October 6, 2011. The parties shall file a Joint Case 5 Management Statement on or before September 29, 2011. 6 7 DATED: March ___, 2011. 3 8 9 10 11 __________________________________________ THE HONORABLE RICHARD SEEBORG UNITED STATES DISTRICT COURT JUDGE
DAVIS WRIGHT TREMAINE LLP
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ORDER Case No. CV 09-04565 RS
DWT 16638856v1 0050411-000105
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