Pineda v. Target Corporation

Filing 33

STIPULATION AND ORDER Discovery due by 9/29/2011. Motion Hearing set for 10/21/2011 10:00 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Samuel Conti. Pretrial Conference set for 11/18/2011 10:00 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Samuel Conti.. Signed by Judge Samuel Conti on 5/18/11. (tdm, COURT STAFF) (Filed on 5/18/2011)

1 GAIL C. TRABISH, ESQ. (SBN 103482)
BOORNAZIAN, JENSEN & GARTHE
2 A Professional Corporation
555 12th Street, Suite 1800
3 Oakland, CA 94607
Telephone: [phone]
4 Facsimile: [phone]
5 Attorneys for Defendant
TARGET CORPORATION
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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11 KHARYL PINEDA, a minor by and through )
KATHERINE PINEDA, his guardian ad
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12 litem
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Plaintiff,
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14 vs.
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15 TARGET CORPORATION and Does 1 and )
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Defendants.
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Case No.: C10-04174 SC
[San Mateo Superior Court Case CIV 497711]

STIPULATION AND ORDER
EXTENDING DEADLINES AND
PRE_TRIAL CONFERENCE
Complaint Filed: August 9, 2010

COMES NOW plaintiff KHARYL PINEDA, a minor by and through KATHERINE

19 PINEDA, his guardian ad litem and defendant TARGET CORPORATION, by and through their
20 attorneys of record and stipulate to extend the following deadlines due to the change in trial date
21 from August 28, 2011 to November 28, 2011, with the new dates as follows:
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Simultaneous expert disclosure: August 10, 2011

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Rebuttal expert disclosure: August 30, 2011

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Last date to complete discovery and take depositions: September 29, 2011

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Last date to hear motions: October 21, 2011

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Pre-trial disclosure pursuant to FRCP 26(a)(3): October 27, 2011

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Last date to serve trial briefs, motions in limine, list of witness and experts; last date to

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-1STIPULATION AND ORDER

– Case No. C10-04174 SC

1 serve and file statement of designating excerpts from depositions; last date to exchange copies of
2 exhibits: November 14, 2011.
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Last date to e-file proposed voir dire, proposed jury instructions, proposed findings of fact

4 and conclusions of law and form of judgment: November 15, 2011.
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In light of the above, the parties request that the court order a new date for the pre-trial

6 conference for a date convenient to the court’s calendar after November 15, 2011.
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9 DATED: May 13, 2011
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By: ______/s/_________________________
ROBERT J.A. FORDIANI, Esq.
Attorney for Plaintiffs
KHARYL PINEDA, a minor by and
through KATHERINE PINEDA, his
guardian ad litem

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DATED: May 13, 2011
BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation
By: ______/s/_________________________
Gail C. Trabish, ESQ
Attorneys for Defendant
TARGET CORPORATION

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-2STIPULATION AND ORDER

– Case No. C10-04174 SC

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ORDER

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Pursuant to the stipulation of the parties,

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IT IS HEREBY ORDERED:
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11/18/11 @ 10:00 a.m.
and a new date and time is set as follows: ____________________________.

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-3STIPULATION AND ORDER

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Judge S

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onti

amuel C

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By: ________________________________
RED
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U. S. District JudgeDE
IT IS S
SAMUEL CONTI

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DATED: May 18, 2011
UNIT
ED

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The Pre-Trial Conference presently scheduled for August 26, 2011 is vacated

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– Case No. C10-04174 SC

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