Nguyen v. Clean Harbors Environmental Services, Inc.

Filing 29

STIPULATION AND ORDER TO CONTINUE THE PARTIES' EXPERT DISCLOSURE DEADLINES BY 30 DAYS re 28 STIPULATION WITH PROPOSED ORDER. Signed by Chief Judge James Ware on July 20, 2012. (wsn, COURT STAFF) (Filed on 7/20/2012)

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1 Michael R. Bracamontes (SBN 242655)
Ryan J. Vlasak (SBN 241581)
2 Kristen M. Ross (SBN 250917)
BRACAMONTES & VLASAK, P.C.
3 220 Montgomery Street, Suite 870
San Francisco, CA 94104
4 Phone: [phone]
Fax: [phone]
5 [e-mail]

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6 Attorneys for Plaintiff Chi Nguyen

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

Bracamontes & Vlasak

A Professional Law Corporation
www.bvlawsf.com

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12 CHI NGUYEN,
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Plaintiff,

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vs.

15 CLEAN HARBORS ENVIRONMENTAL
16 SERVICES, INC., et al.,
Defendants.

17

CASE NO.: CV-11-756-JW
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE THE PARTIES’ EXPERT
DISCLOSURE DEADLINES BY 30 DAYS
Motion To Be Decided on Papers
DEPT: Courtroom 9, 19th Floor
JUDGE: Hon. James Ware
ACTION FILED: February 18, 2011
TRIAL DATE:
None

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IT IS HEREBY STIPULATED AND AGREED by and among all parties that:

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The parties’ deadline to serve and lodge expert witness reports, and all related expert disclosures

21 per Federal Rule of Civil Procedure 26, shall be continued by 30 days.
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A continuance is required because Defendant has represented that a key witness, Scott Brunn, is

23 currently unavailable and on medical leave. Plaintiff believes Mr. Brunn’s testimony is necessary to
24 properly and adequately prepare expert witnesses.

Additionally, on July 16, 2012, Defendants

25 produced over 3,000 additional documents. The parties believe review of these previously undisclosed
26 documents is necessary to properly and adequately prepare expert witnesses.
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28 ///
________________________________________
-1Nguyen v. Clean Harbors Environmental Services, Inc., et al. – Stipulation and [Proposed] Order to Continue the
Parties’ Expert Disclosure Deadlines by 30 Days.
CV-11-756-JW

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IT IS SO STIPULATED AND AGREED.

2
3 DATED: _______________________
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5

___________________________
Michael R. Bracamontes, Esq.
Bracamontes & Vlasak, P.C.
Attorneys for Plaintiff

6
7 DATED: _______________________
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9

___________________________
Jamerson C. Allen, Esq.
Jackson Lewis, LLP
Attorney for Defendant

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Bracamontes & Vlasak

A Professional Law Corporation
www.bvlawsf.com

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12 IT IS SO ORDERED that:
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1. The parties shall serve and lodge expert witness reports by September 10, 2012.

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2. The parties’ deadline to file a Motion to Exclude Expert Witnesses shall be September 13, 2012.

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3. The parties’ deadline to disclose rebuttal expert witnesses shall be September 24, 2012.

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4. The parties’ deadline to file a Motion to Exclude Rebuttal Expert Witnesses shall be September

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27, 2012.
5. The last day for a hearing on a party’s Motion to Exclude an Expert Witness shall be October
17, 2012.
6. The last day for a hearing on a party’s Motion to Exclude a Rebuttal Expert Witness shall be
November 1, 2012.

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23
24 Dated: July 20, 2012
25

____________________________
Hon. James Ware
Chief Judge of the U.S. District Court

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-2Nguyen v. Clean Harbors Environmental Services, Inc., et al. – Stipulation and [Proposed] Order to Continue the
Parties’ Expert Disclosure Deadlines by 30 Days.
CV-11-756-JW