Trujillo v. GT USA, Inc

Filing 43

ORDER GRANTING STIPULATED REQUEST EXTENDING DISCOVERY & EXPERT DEADLINES. The parties' stipulation to extend discovery deadlines is granted. Signed by Judge Maxine M. Chesney on August 31, 2010. (mmclc2, COURT STAFF) (Filed on 8/31/2010)

Trujillo v. GT USA, Inc

Doc. 43

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ROBERT M. LIEBER, ESQ. (SBN: 039976) MARGOLIS & TISMAN LLP 601 Montgomery Street, Suite 2030, San Francisco, California 94111 Telephone [phone] Facsimile: [phone] [e-mail] Attorneys for Defendant & Counterclaimant GT USA, INC. DONALD F. DRUMMOND, ESQ. (SBN: 052986) DRUMMOND & ASSOCIATES 201 Mission Street, Suite 1330 San Francisco, CA 94105 Telephone [phone] Facsimile: [phone] [e-mail] Attorneys for Plaintiff & Counterdefendant CHRISTINA TRUJILLO UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION CHRISTINA TRUJILLO, Plaintiff, v. GT USA, INC., Defendant. Action Filed: November 2, 2009 Trial Date: February 22, 2011 GT USA, INC., Counterclaimant, v. CHRISTINA TRUJILLO, Counterdefendant. Case No. CV 09-05179 MMC STIPULATED REQUEST & [PROPOSED] ORDER EXTENDING DISCOVERY & EXPERT DEADLINES; DECLARATION OF ROBERT M. LIEBER [Fed. R. Civ. Proc. 29(b); Civ. L.R. 6-2]

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MARGOLIS & TISMAN LLP
ATTORNEYS AT LAW -------------------601 MONTGOMERY STREET SUITE 2030 SAN FRANCISCO CALIFORNIA 94111

_________________________________________

STIPULATED REQUEST EXTENDING DISCOVERY & EXPERT DEADLINES

Case No. CV 09-05179-MMC

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MARGOLIS & TISMAN LLP
ATTORNEYS AT LAW -------------------601 MONTGOMERY STREET SUITE 2030 SAN FRANCISCO CALIFORNIA 94111

STIPULATION OF THE PARTIES WHEREAS, pursuant to the Court's Pretrial Preparation Order dated March 29, 2010 (docket no. 29), the non-expert discovery cutoff is currently September 10, 2010, the deadline to designate experts is October 1, 2010, the deadline to designate rebuttal experts is October 15, 2010, and the expert discovery cutoff is November 5, 2010; WHEREAS, the Parties wish to engage in mediation to determine if settlement of this case without trial is possible before engaging in extensive discovery or incurring expert fees; WHEREAS, the mediation of this action has been scheduled to occur on September 15, 2010; WHEREAS, because of the trial and vacation schedules of the Parties' counsel and the assigned mediator, and because Defendant's representative resides in Italy, it was not feasible to hold the mediation earlier; WHEREAS, the discovery and expert deadlines have not previously been extended in this case; WHEREAS, continuing these deadlines would not delay the trial date or otherwise affect the schedule for this case; THEREFORE, pursuant to Federal Rule of Civil Procedure 29(b) and Civil Local Rule 6-2, the parties to this action, by and through their counsel of record, do HEREBY STIPULATE AND REQUEST THE COURT TO ORDER as follows: (1) The non-expert discovery cutoff is extended from September 10, 2010 to November 10, 2010; (2) The deadline to designate experts is extended from October 1, 2010 to December 1, 2010; (3) The deadline to designate rebuttal experts is extended from October 15, 2010 to December 15, 2010; and

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STIPULATED REQUEST EXTENDING DISCOVERY & EXPERT DEADLINES

Case No. CV 09-05179-MMC

Printed on Recycled Paper

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MARGOLIS & TISMAN LLP
ATTORNEYS AT LAW -------------------601 MONTGOMERY STREET SUITE 2030 SAN FRANCISCO CALIFORNIA 94111

(4) The expert discovery cutoff is extended from November 5, 2010 to January 5, 2011. IT IS SO STIPULATED. Dated: August 27, 2010 MARGOLIS & TISMAN LLP By: /s/ Robert M. Lieber ROBERT M. LIEBER Attorneys for Defendant & Counterclaimant GT USA, INC.

Dated: August 27, 2010

DRUMMOND & ASSOCIATES /s/ Donald F. Drummond DONALD F. DRUMMOND Attorneys for Plaintiff & Counterdefendant CHRISTINA TRUJILLO By:

[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. (1) The non-expert discovery cutoff is extended from September 10, 2010 to November 10, 2010; (2) The deadline to designate experts is extended from October 1, 2010 to December 1, 2010; (3) The deadline to designate rebuttal experts is extended from October 15, 2010 to December 15, 2010; and (4) The expert discovery cutoff is extended from November 5, 2010 to January 5, 2011.

August 31, 2010 Dated: _______________ By HON. MAXINE M. CHESNEY United States District Court Judge

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STIPULATED REQUEST EXTENDING DISCOVERY & EXPERT DEADLINES

Case No. CV 09-05179-MMC

Printed on Recycled Paper