Albrect v. Watson Pharmaceuticals et al

Filing 34

STIPULATION AND ORDER Continuing Date of Deposition Discovery Cutoff. Signed by Judge Thelton E. Henderson on 01/09/2012. (tmi, COURT STAFF) (Filed on 1/9/2012)

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JENNIFER SCHWARTZ (SBN 135932)
LAW OFFICES OF JENNIFER SCHWARTZ
1299 Fourth St., Suite 307
San Rafael, CA 94901
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for PLAINTIFF
ANNE ALBRECHT
MARY E. WRIGHT (SBN 142886)
[e-mail]
JEAN C. KOSELA (SBN 252753)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Tel: [phone]
Fax: [phone]
Attorneys for Defendants
WATSON PHARMACEUTICALS and
WATSON PHARMACEUTICALS (NEW JERSEY), INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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STIPULATION AND (PROPOSED)
ORDER CONTINUING DATE OF
DEPOSITION DISCOVERY CUTOFF

Plaintiff,

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Case No. CV 10-05272 TEH

ANNE ALBRECHT, an individual,

vs.

Complaint Filed: September 8, 2010
Trial Date: July 10, 2012

WATSON PHARMACEUTICALS, a
Delaware Corporation; WATSON
PHARMACEUTICALS (NEW JERSEY),
INC., a New Jersey Corporation; and DOES 1
through 50, inclusive,
Defendants.

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STIPULATION AND (PROPOSED) ORDER CONTINUING DATE OF DEPOSITION DISCOVERY CUTOFF
CASE NO. CV 10-05272 TEH

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WHEREAS, the trial of this matter is currently set for July 10, 2012;
WHEREAS, December 31, 2011 was the discovery cutoff date;
WHEREAS, the Court previously approved a stipulation allowing the parties to extend

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the discovery cutoff for depositions until January 31, 2012 in order to conduct a mediation on

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December 14, 2011;

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WHEREAS, the case did not settle at the December 14 mediation but the parties desire
to continue mediation of the matter and have confirmed with the mediator that they will be able
to do so on or before February 10, 2012;

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WHEREAS, the parties have an expectation that the matter may resolve at the second
day of mediation;
WHEREAS, the parties have scheduled over 15 depositions for the month of January,

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beginning Monday, January 9, and wish to take those depositions off calendar pending potential

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settlement of this matter at mediation;

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WHEREAS,

if no settlement occurs, the parties will have

to reschedule depositions for February and early March;
WHEREAS, given the July 10, 2012 trial date, the parties believe that other major pretrial dates can be continued without impacting either the trial date;
THEREFORE, THE PARTIES, BY AND THROUGH THEIR ATTORNEYS OF
RECORD, HEREBY STIPULATE AND AGREE:
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To continue the discovery cut-off for depositions to March 5, 2012 so long as any
such depositions are noticed prior to February 6, 2012.

2. To the following schedule for other pretrial dates and for briefing of dispositive
motions;

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STIPULATION AND (PROPOSED) ORDER CONTINUING DATE OF DEPOSITION DISCOVERY CUTOFF
CASE NO. CV 10-05272 TEH

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Pretrial motions hearing (Last day to hear pretrial motions except motions in

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limine): April 23

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Last day for filing dispositive motions: March 12

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Expert Discovery Cutoff: April 15
Pretrial conference: June 25 (no change requested for this date)
Trial: July 10 (no change requested for this date)

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Deadline for filing opposition to dispositive motions: April 2
Deadline for filing reply to dispositive motion: April 9

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SO STIPULATED,

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DATED: January 6, 2011

LAW OFFICES OF JENNIFER SCHWARTZ

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By:_________/S/_______________________
Jennifer Schwartz
Attorney for Plaintiff
ANNE ALBRECHT

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DATED: January 6, 2011

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By:________/S/________________________
Mary E. Wright
Attorneys for Defendants
WATSON PHARMACEUTICALS et al.

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__________________________________
THELTON E. HENDERSON, JUDGE
UNITED STATES DISTRICT COURT

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DATED: 01/09/2012

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IT IS SO ORDERED.

UNIT
ED

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STIPULATION AND (PROPOSED) ORDER CONTINUING DATE OF DEPOSITION DISCOVERY CUTOFF
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CASE NO. CV 10-05272 TEH