Orosa v. Therakos, Inc. et al

Filing 60

STIPULATION AND ORDER re 58 MODIFYING FIRST AMENDED CASE MANAGEMENT AND PRETRIAL ORDER, AS TO DISCOVERY CUTOFF DATE AND OTHER DIRECTLY RELATED DATES filed by Charo Orosa. Discovery due by 1/14/2013. Dispositive Motion Hearing set for 3/21/2013 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen.. Signed by Judge Edward M. Chen on 12/11/12. (bpf, COURT STAFF) (Filed on 12/11/2012)

Download PDF
1 4 Michael T. Welch (#122630) LAW OFFICES OF MICHAEL T. WELCH Four Embarcadero Center, 39th Floor San Francisco, California 94111 Tel: (415) 399-1500 Fax: (415) 399-0445 Email: mw@mwelchlaw.com 5 Attorneys for Plaintiff CHARO OROSA 6 10 L. Julius M. Turman, SBN 226126 Philip J. Smith, SBN 232462 MORGAN, LEWIS & BOCKIUS LLP One Market, Spear Street Tower San Francisco, CA 94105-1126 Tel: (415)442-1000 Fax: (415)442-1001 Email: jturman@morganlewis.com Email: philip.smith@morganlewis.com 11 Attorneys for Defendants THERAKOS, INC. and JOHNSON & JOHNSON, INC. 2 3 7 8 9 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 15 16 17 18 19 20 21 22 CHARO OROSA, an Individual, ) ) Plaintiff, ) ) v. ) ) THERAKOS INC., a corporation; JOHNSON ) & JOHNSON, INC., a corporation, ) ) Defendant ) ) ______________________________________ ) CASE NO. CV-11-02143 EMC STIPULATION AND PROPOSED ORDER MODIFYING FIRST AMENDED CASE MANAGEMENT CONFERENCE AND PRETRIAL ORDER FOR JURY TRIAL, AS TO DISCOVERY CUTOFF DATE AND OTHER DIRECTLY RELATED DATES (as modified) 23 24 25 26 27 28 -1STIPULATION AND PROPOSED ORDER MODIFYING FIRST AMENDED CASE MANAGEMENT CONFERENCE AND PRETRIAL ORDER FOR JURY TRIAL, AS TO DISCOVERY CUTOFF DATE AND OTHER DIRECTLY RELATED DATES 1 Plaintiff CHARO OROSA (“OROSA”) and defendants THERAKOS, INC. 2 (“THERAKOS”) and JOHNSON & JOHNSON, INC. (“J&J”) (collectively referred to as “the 3 Parties”) hereby stipulate to, and request that the Court accept the stipulation of counsel for a 4 change to the Case Management Scheduling Order as provided and based on the following 5 grounds: 6 Due to the unavailability of defendants’ counsel due to other trial and related matters in 7 recent weeks and continuing through December, 2012, which has had and will continue to have 8 the effect of delaying the ability of plaintiff’s counsel to complete his remaining discovery, 9 particularly a number of out-of-state depositions, before the currently scheduled discovery cut-off 10 date of December 7, 2012, and plaintiff’s counsel’s willingness and desire to accommodate the 11 schedule of defendants’ counsel that presents this conflict, the parties hereby stipulate, and 12 request that the Court accept the parties’ stipulation, to modify the current First Amended Case 13 Management Conference And Pretrial Order for Jury Trial so that the discovery cutoff date, and 14 related pretrial event dates affected by that cutoff date, are extended as follows: 15 16 17 1. The Non-Expert Discovery Cutoff is extended from the prior date of December 7, 2012, to January 14, 2013; 2. The Expert Reports - Opening reports due date is extended from the prior date of 18 December 7, 2012, to January 14, 2013, and the Rebuttal reports due date is extended from the 19 prior date of December 28, 2012 to February 4, 2013; 20 3. The Expert Discovery Cut-off is extended from January 18, 2013 to February 18, 21 2013; and 22 23 4. The last day for Dispositive Motions to be heard is extended from March 1, 2013 at 21 1:30 P.M., to March 29, 2013 at 1:30 P.M.. 24 All other pre-trial and trial dates shall remain the same as currently scheduled in the First 25 26 Amended Case Management Conference And Pretrial Order For Jury Trial. IT IS SO STIPULATED. 27 28 -2STIPULATION AND PROPOSED ORDER MODIFYING FIRST AMENDED CASE MANAGEMENT CONFERENCE AND PRETRIAL ORDER FOR JURY TRIAL, AS TO DISCOVERY CUTOFF DATE AND OTHER DIRECTLY RELATED DATES 1 DATED: December 6, 2012 LAW OFFICES OF MICHAEL T. WELCH 2 3 By: /S/ Michael Welch Michael T. Welch Attorneys for Plaintiff CHARO OROSA 4 5 6 DATED: December 6, 2012 MORGAN, LEWIS & BOCKIUS LLP 7 8 By:_/S/ Julius M. Turman L. Julius M. Turman Philip J. Smith Attorneys for Defendants THERAKOS, INC. and JOHNSON & JOHNSON 9 10 11 12 PURSUANT TO STIPULATION, IT IS SO ORDERED. ERED O ORD D ____________________________________ IT IS S The Honorable Edward M.DIFIE AS MO Chen R NIA 16 UNIT ED 15 11 Dated: December ___, 2012 S DISTRICT TE C TA RT U O 14 S 13 United States District Judge ER 20 A H 19 Chen LI RT 18 dw Judge E FO ard M. NO 17 N F D IS T IC T O R C 21 22 23 24 25 26 27 28 -3STIPULATION AND PROPOSED ORDER MODIFYING FIRST AMENDED CASE MANAGEMENT CONFERENCE AND PRETRIAL ORDER FOR JURY TRIAL, AS TO DISCOVERY CUTOFF DATE AND OTHER DIRECTLY RELATED DATES

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?