Dodge v. FoodMatch, Inc.

Filing 18

ORDER GRANTING AS MODIFIED 17 STIPULATION To Continue The Deadlines for Discovery Cutoff and Disclosure of Final Round of Experts. Discovery due by 8/1/2013. Expert Witness List due by 8/29/2013. Jury Selection set for 1/8/2014 08:00 AM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White. Jury Trial set for 1/13/2014 08:00 AM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White. Motion Hearing set for 10/11/2013 09:00 AM in Courtroom 11, 19th Fl oor, San Francisco before Hon. Jeffrey S. White. Pretrial Conference set for 12/16/2013 02:00 PM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White.. Signed by Judge JEFFREY S. WHITE on 4/8/13. (jjoS, COURT STAFF) (Filed on 4/8/2013) Modified on 4/8/2013 (jjoS, COURT STAFF).

Case3:12-cv-03650-JSW Document17 Filed04/02/13 Page1 of 3

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LAW OFFICES OF STEPHEN M. MURPHY
STEPHEN M. MURPHY (No. 103768)
P. BOBBY SHUKLA (No. 229736)
353 Sacramento Street, Suite 1140
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiff
MICHAEL DODGE

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FARBSTEIN & BLACKMAN
A Professional Corporation
MICHAEL A. FARBSTEIN (No. 107030)
MAGGIE W. TRINH (No. 279604)
411 Borel Avenue, Suite 425
San Mateo, California 94402-3518
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
FOODMATCH, INC.
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MICHAEL DODGE,
Plaintiff,

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v.

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Case No. CV 12-03650 JSW
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE THE
DEADLINES FOR DISCOVERY
CUTOFF AND DISCLOSURE OF FINAL
ROUND OF EXPERTS

FOODMATCH, INC., and DOES ONE
through TWENTY, inclusive,

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Defendants.
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Plaintiff MICHAEL DODGE (“Plaintiff”) and Defendant FOODMATCH, INC.

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(“Defendant”) by and through their counsel of record herein, hereby stipulate and agree as

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follows:
Case No. CV 12-03650 JSW
Page 1
STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY CUT-OFF AND DEADLINES FOR
DISCLOSURE OF FINAL ROUND OF EXPERTS

Case3:12-cv-03650-JSW Document17 Filed04/02/13 Page2 of 3

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WHEREAS, the Court issued a Civil Minute Order on November 16, 2012, ordering the

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parties to, among other things, complete discovery by April 29, 2013 and disclose their final

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round of experts by May 14, 2013;

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WHEREAS, the parties participated in a mediation on February 14, 2013 before Robert
Fries, Esq. and delayed commencement of discovery pending the results of the mediation;

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WHEREAS, the parties were unsuccessful in resolving the case at mediation;

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WHEREAS, the parties have been diligently attempting to comply with the Court’s

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pretrial order but need additional time to complete discovery, including depositions;

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WHEREAS, the parties need additional time to retain and prepare experts prior to
disclosure;

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WHEREAS, the parties wish to have an opportunity to discuss settlement before retaining
and obtaining reports from all experts;

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WHEREAS, the parties agree that continuing the current pre-trial deadlines will not
prejudice any party in this case;

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NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE to extend

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the following pre-trial deadlines set by the Court on November 16, 2012, by approximately three

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months as follows:

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1. Close of Fact Discovery from April 29, 2013 to August 1, 2013

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2. Last Day to Disclose Experts from May 14, 2013 to August 15, 2013

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3. Close of Expert Discovery from May 29, 2013 to August 29, 2013

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4. Hearing Dispositive Motions from August 16, 2013 at 9:00 a.m. to October 20, 2013

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at 9:00 a.m.

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5. Pre-trial Conference from November 12, 2013 at 2:00 p.m. to November 25, 2013 at

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2:00 p.m.

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///

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///

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///

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///
Case No. CV 12-03650 JSW
Page 2
STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY CUT-OFF AND DEADLINES FOR
DISCLOSURE OF FINAL ROUND OF EXPERTS

Case3:12-cv-03650-JSW Document17 Filed04/02/13 Page3 of 3

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The Court CONTINUES
to January 8, 2014
The parties do not propose any changes to the dates set for Jury Selection (December 4,
to January 13, 2014
2013 at 8:00 a.m.) or Jury Trial (December 9, 2013 at 8:00 a.m.).
Dated: April 2, 2013

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LAW OFFICES OF STEPHEN M. MURPHY
By:

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/s/ P. Bobby Shukla
STEPHEN M. MURPHY
P. BOBBY SHUKLA
Attorneys for Plaintiff
MICHAEL DODGE

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Dated: April 2, 2013

FARBSTEIN & BLACKMAN

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By:
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IT IS SO ORDERED.

/s/ Michael A. Farbstein ____
MICHAEL A. FARBSTEIN
Attorneys for Defendant
FOODMATCH, INC.

AS MODIFIED ABOVE.

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Dated: April ___, 2013

By:________________________________
JEFFREY S. WHITE
UNITED STATES DISTICT JUDGE

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Case No. CV 12-03650 JSW
Page 3
STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY CUT-OFF AND DEADLINES FOR
DISCLOSURE OF FINAL ROUND OF EXPERTS