Gitterman v. Experian Information Solutions Inc

Filing 39

STIPULATION AND ORDER RE 37 TO EXTEND DEADLINES. Stipulation filed by Experian Information Solutions Inc. Signed by Judge Richard Seeborg on 3/2/11. (cl, COURT STAFF) (Filed on 3/2/2011)

Gitterman v. Experian Information Solutions Inc

Doc. 39

*E-Filed 3/2/11*

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Angela M. Taylor (CA Bar No. 210425) [e-mail] Eric J. Hardeman (SBN 253489) [e-mail] JONES DAY 3 Park Plaza, Suite 1100 Irvine, CA 92614 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant EXPERIAN INFORMATION SOLUTIONS, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

HEIDI GITTERMAN, Plaintiff, v. EXPERIAN INFORMATION SOLUTIONS, INC., Defendant.

Case No. CV-09-05382 RS STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER [LOCAL RULE 6-1]

16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff Heidi Gitterman ("Plaintiff") and Defendant Experian Information Solutions, Inc. ("Experian"), by and through their respective attorneys of record, hereby STIPULATE to modify the Court's Case Management Scheduling Order (Docket No. 27) to extend the deadline for completion of non-expert discovery from March 15, 2011, by sixty days, to May 14, 2011. Good cause exists to extend the discovery deadline because the parties' counsel were unable to coordinate written discovery and depositions due to scheduling conflicts with their respective counsel. Daniel Dobrygowski, Experian's former attorney in this case, has recently left the law firm of Experian's counsel, Jones Day, and was also unavailable to coordinate discovery at the beginning of this year after his wife gave birth. In addition, Plaintiff's attorney Christopher Saldaņa was involved in two trials in southern California lasting approximately two months at the beginning of this year. This is the first request by the parties to extend the pre-trial deadlines in this case, and the parties submit that all non-expert discovery will be completed on or
IRI-17600v1

STIPULATION TO EXTEND DISCOVERY DEADLINE CASE NO. CV 09-05382 RS

Dockets.Justia.com

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before May 14, 2011. Dated: March 1, 2011 JONES DAY

By: /s/ Eric J. Hardeman Eric J. Hardeman Attorneys for Defendant EXPERIAN INFORMATION SOLUTIONS, INC. Dated: March 1, 2011 SHEWRY & VAN DYKE, LLP

By: /s/ Christopher C. Saldaņa Christopher C. Saldaņa Attorneys for Plaintiff HEIDI GITTERMAN

IT IS SO ORDERED. 3/2 Dated: ____________, 2011 _____________________________________ UNITED STATES DISTRICT JUDGE NORTHERN DISTRICT OF CALIFORNIA

IRI-17600v1

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STIPULATION TO EXTEND DISCOVERY DEADLINE CASE NO. CV 09-05382 RS