Kelleher v. Kelleher et al

Filing 106

ORDER by Magistrate Judge Maria-Elena James finding as moot 104 Stipulation; granting 105 Stipulation (rmm2S, COURT STAFF) (Filed on 3/16/2015)

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Kenneth Frucht, SBN 178881
Frederick J. Geonetta, SBN 114824
Geonetta & Frucht LLP
100 Montgomery Street, 16th Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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AMBER KELLEHER,
Plaintiff,

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v.

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JOHN E. KELLEHER, et al,

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Defendants.

) CASE NO. CV 13-5450
)
ddd
)
)
D
)
FIRST REVISED STIPULATION AND
) (PROPOSED) ORDER CONTINUING
) DEADLINES FOR DISCOVERY AND
) DISPOSITIVE MOTIONS (L.R. 6-2 and 7-12)
)

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STIPULATON

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WHEREAS, Plaintiff has conducted extensive written discovery and started taking
deposition testimony;
WHEREAS, it has become clear to the parties that additional discovery is necessary,

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including the scheduling and taking of several depositions of important out-of-state witnesses that

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must be taken in the State of Montana;

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WHEREAS, the Montana depositions must accommodate the schedules of the out-of-state
witnesses;
WHEREAS, the parties are in agreement that the necessary discovery cannot be completed

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before the current discovery cutoff and therefore wish to request the Court to extend the deadline for

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close of discovery from the current March 10, 2015 to April 30, 2015;
Northern Dist. Court Case No. 13-5450

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WHEREAS, the parties have cleared a trial date with the Court and are in agreement that the
matter should be tried starting on December 14, 2015;
WHEREAS, there have been no previous time modifications in the case, whether by
stipulation or Court order;

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NOW THEREFOR, the parties declare, stipulate and agree as follows:

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1) All discovery shall be completed by April 30, 2015;

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2) Any and all dispositive motions must be filed by May 28, 2015

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3) The trial and remaining pretrial dates set by the Scheduling Order dated September 30,

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2014 (Docket No. 93) shall be modified as follows:

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Event

Date per Scheduling
Order dated
September 30, 2015

New schedule

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Close of Discovery

3/10/2015

4/30/2015

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Deadline to File Dispositive
Motions
Hearing on Dispositive
Motions
Exchange of Pre-trial
Disclosures
Deadline to File Pretrial
Conference Statement and
Related Disclosures, Motions
in Limine, and Trial Briefs and
Related Documents
Deadline to File Motions in
Limine Oppositions
Pretrial Conference

4/9/2015

5/28/2015

5/14/2015

7/2/2015 at 10:00 a.m. (Thurs)

7/15/2015

9/30/2015

7/30/2015

10/15/2015

8/6/2015

10/22/2015

8/20/2015

11/5/2015 at 10:00 a.m. (Thurs)

Final Pretrial Conference
(FPC)
Trial

9/17/2015

12/3/2015 at 10:00 a.m. (Thurs)

9/28/2015

12/14/2015 at 9:30 a.m.
(Duration: 5 days) (Mon.

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Northern Dist. Court Case No. 13-5450

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Dated: March 9, 2015

For Plaintiff Amber Kelleher

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By: __ /s/ Jay D. Adkisson ________
Jay D. Adkisson
Riser Adkisson, LLP

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Dated: March 9, 2015

For Defendant John Kelleher

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By: __ /s/ Frederick J. Geonetta _____
Frederick J. Geonetta
Geonetta & Frucht, LLP

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PURSUANT TO STIPULATION, IT IS SO ORDERED

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Dated

March 16, 2015

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By: _________________________
Maria Elena James
United States Magistrate Judge

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Northern Dist. Court Case No. 13-5450

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