Gitterman v. Experian Information Solutions Inc

Filing 43

STIPULATION AND ORDER RE 42 TO MODIFY CASE MANAGEMENT SCHEDULING ORDER. Signed by Judge Richard Seeborg on 3/30/11. (cl, COURT STAFF) (Filed on 3/30/2011)

Gitterman v. Experian Information Solutions Inc

Doc. 43

*E-Filed 3/30/11* 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 The Plaintiff, HEIDI GITTERMAN ("Plaintiff" or "Gitterman"), by and through her 18 attorneys of record, Shewry & Van Dyke, LLP, and the Defendant, EXPERIAN INFORMATION 19 SOLUTIONS, INC. ("Experian"), by and through its attorneys, Jones Day, Plaintiff Heidi Gitterman 20 ("Plaintiff") and Defendant Experian Information Solutions, Inc. ("Experian"), by and through their 21 respective attorneys of record, hereby STIPULATE to modify the Court's Case Management 22 Scheduling Order [Doc. Nos. 27 & 39] to extend the deadline for completion of non-expert discovery 23 by sixteen (16) days, from May 14, 2011 to May 31, 2011. In anticipation of the Court's grant of 24 this request, Experian has granted to Plaintiff a two-week extension of time within which to respond 25 to Experian's written discovery requests. 26 The parties agree that good cause exists to extend the discovery deadline. After service by 27 Experian in early March, 2011 of written discovery, Plaintiff's mother fell ill and thereafter passed 28
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Michelle Van Dyke, Esq. (SBN 171477) E-mail: [e-mail] Christopher C. Saldaņa, Esq. (SBN 269456) E-mail: [e-mail] SHEWRY & VAN DYKE, LLP 402 West Broadway, Suite 950 San Diego, California 92101-8504 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff HEIDI GITTERMAN

UNITED STATES DISTRICT COURT IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA HEIDI GITTERMAN, an individual ) ) Plaintiff, ) ) vs. ) ) ) EXPERIAN INFORMATION ) SOLUTIONS, INC., an Ohio corporation ) doing business as EXPERIAN; and DOES ) ONE through TEN, inclusive, ) ) Defendants. ) ____________________________________) Case No.: 3:09-cv-05382-RS STIPULATION TO MODIFY CASE MANAGEMENT SCHEDULING ORDER; [PROPOSED] ORDER THEREON [Civil L.R. 6-1; 6-2; 7-12]
District Judge: Courtroom: Hon. Richard Seeborg 3

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STIPULATION TO M ODIFY CASE M ANAGEM ENT SCHEDULING ORDER; [PROPOSED] ORDER

Dockets.Justia.com

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away. Due to the extreme emotional difficulties endemic in such situations, and other concomitant considerations, Plaintiff has been unable to fully participate in the preparation of responses during the time frames set forth under the Federal Rules of Civil Procedure. This current state of affairs was not one reasonably foreseeable by the parties or their counsel. This is the second request of the parties to modify the Case Management Scheduling Order [See Doc. Nos. 38 & 39], adding a total of 74 days to the dates initially set forth in Doc. No. 27. The parties anticipate that all non-expert discovery will be concluded by June 6, 2011. DATED: March 29, 2011 SHEWRY & VAN DYKE, LLP By /s/ Christopher C. Saldaņa Christopher C. Saldaņa, Esq. Michelle L. Van Dyke, Esq. Attorneys for Plaintiff HEIDI GITTERMAN JONES DAY By /s/ Eric J. Hardeman Eric J. Hardeman, Esq. Angela M. Taylor, Esq. Attorneys for Defendant EXPERIAN INFORMATION SOLUTIONS, INC. ORDER

10 11 12 DATED: March 29, 2011 13 14 15 16 17 18

PURSUANT TO STIPULATION, IT IS SO ORDERED. 19 20 Dated: ____________________ 3/30/11 21 22 23 24 25 26 27 28
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_________________________________________ UNITED STATES DISTRICT JUDGE NORTHERN DISTRICT OF CALIFORNIA

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STIPULATION TO M ODIFY CASE M ANAGEM ENT SCHEDULING ORDER; [PROPOSED] ORDER