Montenegro v. Wan Hai Lines (Singapore) PTE LTD
Filing
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ORDER GRANTING re 36 Stipulation and Order Setting Certain Pretrial Deadlines filed by Wan Hai Lines (Singapore) PTE LTD. Signed, as modified, by Judge Joseph C. Spero on 5/10/11. (klhS, COURT STAFF) (Filed on 5/10/2011)
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Attorneys for Plaintiff
ERIC MONTENEGRO
James B. Nebel/State Bar No.69626
FLYNN, DELICH & WISE LLP
343 Sansome Street, Suite 540
San Francisco, California 94104
Telephone: 415-693-5566
Facsimile: 415-693-0410
Attorneys for Defendant
WAN HAI LINES (SINGAPORE) PTE LTD.
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UNITED STATES DISTRICT COURT
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(562) 435-2626
ATTORNEYS AT LAW
ONE WORLD TRADE CENTER, SUITE 1800
LONG BEACH, CALIFORNIA 90831-1800
FLYNN, DELICH & WISE LLP
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Patrick B. Streb/State Bar No. 116555
WELTIN, STREB & WELTIN
1432 Martin Luther King Jr. Way
Oakland, CA 94612
Telephone: 510-251-6060
Facsimile: 510-251-6040
NORTHERN DISTRICT OF CALIFORNIA
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Plaintiff,
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vs.
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WAN HAI LINES (SINGAPORE) PTE LTD., )
et al.,
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Defendants.
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______________________________________
ERIC MONTENEGRO,
Case No.: C 10-000581 JCS
STIPULATION AND [PROPOSED]
ORDER SETTING CERTAIN PRETRIAL
DATES
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At the Case Management Conference that was held on April 22, 2011, the Court set this
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matter for jury trial to commence on February 6, 2012 at 8:30 a.m. in Courtroom A, 15th Floor.
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The Court also directed the parties to stipulate as to certain other pretrial dates and to submit a
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proposed Order.
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_____________________________________________________________________________________________________
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STIPULATION AND [PROPOSED] ORDER SETTING CERTAIN PRETRIAL DATES
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Accordingly, the parties to this action, plaintiff ERIC MONTENEGRO, and defendant,
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WAN HAI LINES (SINAGAPORE) PTE LTD., by and through their counsel of record, stipulate
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and request the Court to enter an Order as follows.
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DISCOVERY
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1. All non-expert discovery shall be completed by October 1, 2011.
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2. All expert disclosures required by Federal Rules of Civil Procedure shall be made by
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October 15, 2011. Expert rebuttal disclosures shall be completed by November 5,
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2011.
counsel for defendant shall meet and confer in person regarding the subject matter of
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the motion(s) in an effort to resolve these matters. After attempting other means to
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confer on the issue (i.e., letter, phone call, e-mail) any party may demand such a
(562) 435-2626
3. In lieu of filing formal discovery motions, lead trial counsel for plaintiff and lead trial
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ATTORNEYS AT LAW
ONE WORLD TRADE CENTER, SUITE 1800
LONG BEACH, CALIFORNIA 90831-1800
FLYNN, DELICH & WISE LLP
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meeting on ten (10) business days’ notice. The location of the meeting will alternate
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with the first location selected by counsel for plaintiff, the second by counsel for
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defendant, etc. Within five (5) business days of the lead trial counsel’s meet-and-
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confer session, the parties shall provide a detailed joint letter to the Court. This joint
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letter shall include a description of every issue in dispute and, with respect to each such
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issue, a detailed summary of each party’s final substantive position and their final
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proposed compromise on each issue. Upon receipt of the joint letter, the Court will
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determine what future proceedings are necessary.
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MOTIONS
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4. All dispositive motions shall be served and filed not less than thirty-five (35) days prior
1:30 p.m.
to the scheduled hearing date of November 18, 2011, at 9:30 a.m. Any opposition
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shall be served and filed no later than twenty-one (21) days prior to the hearing date.
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Any reply to the opposition shall be served and filed no later than fourteen (14) days
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prior to the date of the hearing.
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With respect to motions for summary judgment, parties shall follow the procedure’s
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outlined in Judge Spero’s standing Order.
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STIPULATION AND [PROPOSED] ORDER SETTING CERTAIN PRETRIAL DATES
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PRETRIAL CONFERENCE
5. A Final Pretrial Conference shall be held on January 27, 2012, at 1:30 p.m., in
Courtroom A, 15th Floor. Each party shall attend by lead trial counsel.
Dated: May 5, 2011
WELTIN, STREB & WELTIN LLP
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/s/ Patrick B. Streb
By __________________________
Patrick B. Streb
Attorneys for Plaintiff
ERIC MONTENEGRO
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FLYNN, DELICH & WISE LLP
/s/ James B. Nebel
By __________________________
James B. Nebel
Attorneys for Defendant
WAN HAI LINES (SINGAPORE) PTE LTD.
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(562) 435-2626
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[PROPOSED] ORDER
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The Court adopts the parties’ stipulated schedule.
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SO ORDERED.
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S DISTRICT
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UNITED STATES MAGISTRATE JUDGE
Spero
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Judge Jo
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NO
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DERED
SO OR ED
IT IS
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___________________________________
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Dated: May __, 2011
A
ATTORNEYS AT LAW
ONE WORLD TRADE CENTER, SUITE 1800
LONG BEACH, CALIFORNIA 90831-1800
FLYNN, DELICH & WISE LLP
Dated: May 5, 2011
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D IS T IC T O
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_____________________________________________________________________________________________________
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STIPULATION AND [PROPOSED] ORDER SETTING CERTAIN PRETRIAL DATES
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