Lloyd et al v. Sjoblom et al

Filing 42

STIPULATION AND ORDER TO CONTINUE EXPERT DISCLOURE DATES re 40 Stipulation filed by Peter Lloyd, Ventor Progress AB. Signed by Judge Jacqueline Scott Corley on 8/27/2014. (tlS, COURT STAFF) (Filed on 8/27/2014)

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Stephen Z. Boren (State Bar No. 192024)
Ayesha A. Mahapatra (State Bar No. 225475)
BOREN, OSHER & LUFTMAN, LLP
5900 Wilshire Boulevard, Suite 920
Los Angeles, California 90036
Telephone: [phone]
FacsImile: [phone]
Attorneys for Plaintiffs and Cross-Defendants
PETER LLOYD, and
VENTOR PROGRESS AB

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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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PETER LLOYD, an individual, )
VENTOR PROGRESS AB a )
Swedish Limited Company,
)
Plaintiff,

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vs.

)

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Defendants.

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)
EURO OFFICE AMERICAS, )
)
INC., a Delaware corporation
)
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Cross-claimant,
)
)
vs.
)
PETER LLOYD, an individual, )
VENTOR PROGRESS AB a )
Swedish Limited Company, )
)
ROES 1 through 20, inclusive
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Cross-defendants.
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STIPULATION TO CONTINUE
EXPERT DISCLOSURE DATES
AND ORDER

)
)
SJOBLOM,
an )
MIKAEL
individual,
EURO
OFFICE )
AMERICAS, INC. a Delaware )
c01l?oration, and DOES 1 through )
20, inclusive,
)

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CASE NO.: CV-14-0234 (JSC)

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Complaint Filed: January 15,2014

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STIPULATION TO CONTINUE EXPERT
DISCLOSURE DATES

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TO THIS HONORABLE COURT:

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RECITALS
WHEREAS, on May 30, 2014, this Court entered a Civil Pretrial Order,

pursuant to which:

(1) initial expert witness disclosures are due on or before

September 1, 2014; (2) rebuttal expert witness disclosures are due on or before
September 14,2014; and (3) the expert discovery cut-off is October 14,2014;
WHEREAS, Defendants and Cross-Complainants are continuing to produce

documents, which Plaintiffs and Cross-Defendants must review and provide to their
expert witness(es) for consideration in connection with any opinions they may
render; and
WHEREAS, the Parties have agreed to continue the expert witness

disclosure and cut-off by thirty (30) days to allow the parties' experts, if any,
sufficient time in which to prepare their reports and provide meaningful deposition
testimony.

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STIPULATION

The Parties, through their counsel of record, hereby stipulate and agree to the
following amendments to this Court's Civil Pretrial Order:
1. Initial Expert Witness Disclosures will be due on or before October 1,
2014;
2. Rebuttal Expert Witness Disclosures will be due on or before October 14,
2014; and

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STIPULATION TO CONTINUE EXPERT
DISCLOSURE DATES

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3. The Expert Discovery Cut-Off shall be November 14,2014.

IT IS SO STIPULATED.

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Dated: August 27, 2014

BOREN, OSHER & LUFTMAN, LLP

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lsi Stephen Z. Boren

By:

STEPHEN Z. BOREN
Attorneys for Plaintiffs and Cross­
Defendants

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Dated: August 27,2014

TIMOTHY THOMAS O'CONNOR

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By:_ _ _.!...!:/s:::.../~T.!-..::::::O--:'C~o~nn=o..:..r_ __
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Attorney for Defendants and Cross­
Complainants

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[PROPOSED) ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED:

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August 27, 2014
DATED: ___________
JACQUELINE SCOTT CORLEY
United States Magistrate Judge

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STIPULATION TO CONTINUE EXPERT
DISCLOSURE DATES

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PROOF OF SERVICE
CASE NO. CV-14-0234 (JSC)

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STATE OF CALIFORNIA

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) ss.
COUNTY OF LOS ANGELES )
I am employed in the County of Los Angeles, State of California. I am over
the age of 18 and not a party to the within action; my business address is [Xl 5900
Wilshire Blvd., Ste. 920, Los Angeles, California 90036.
On August 27,2014, I served the foregoing document(s) described as:

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STIPULATION TO CONTINUE EXPERT DISCLOSURE DATES

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on the interested party(ies) in this action by placing a true copy(ies) thereof,
enclosed in a sealed envelope and addressed as follows:

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T. O'Connor, Esq.
T. O'Connor and Duke
133 Court Street
Auburn, CA 95603
Attorney for Defendants
[Xl (MAIL) I am "readily familiar" with Boren, Osher & Luftman, LLP's practice

of collection and processing correspondence for mailing. Under the practice the
correspondence would be deposited with the U.S. postal service on the same day
with postage thereof fully prepaid at Los Angeles, California in the ordinary course
of business. I am aware that on motion of the party served, service is presumed
invalid if postage cancellation date or postage date is more than one day after date
of deposit for mailing in affidavit.

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[X] (FEDERAL) I declare that I am employed in the offi.::e of a member of the Bar
of this Court at whose direction the service was made. I declare under penalty of
perjury under the laws of the United States that the above is true and correct.

Executed on August 27,2014, at Los Angeles, California

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Hanna Lee
Print or Type Name

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STIPULA TION TO CONTINUE EXPERT
DISCLOSURE DATES