Michael Herrera v. Neff Rental,LLC et al

Filing 80

ORDER by Judge Susan Illston granting 78 STIPULATION WITH PROPOSED ORDER Re Expert Disclosure and Rebuttal Reports. Signed by Judge Susan Illston on 11/6/15. (tfS, COURT STAFF) (Filed on 11/9/2015)

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BIRNBERG & ASSOCIATES
CORY A. BIRNBERG (SBN 105468)
1083 Mission Street Third Floor
San Francisco, California 94103
Telephone Number: [phone]
Facsimile Number: [phone]
Email: [e-mail]
Attorneys for Plaintiff
MICHAEL HERRERA

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MICHAEL HERRERA,

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Plaintiff,
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vs.

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NEFF RENTAL, LLC.,
Defendant,

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and
PORTS INSURANCE COMPANY, INC.,

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Intervening Plaintiff.
___________________________________

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NEFF RENTAL, LLC.,

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Third-Party Plaintiff,
vs.

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BIRNBERG &
ASSOCIATES
1083 MISSION STREET
Third Floor
SAN FRANCISCO
CA, 94103
TEL [phone]
FAX [phone]

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MARINE TERMINALS CORPORATION,
d.b.a. PORTS AMERICA,
Third-Party Defendant.
___________________________________

Case No. Civ- 14-2295 SI

STIPULATION AND [PROPOSED]
ORDER TO CONTINUE EXPERT
WITNESS DISCLOSURES

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT WITNESS DISCLOSURES
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Case No. Civ-14-2295 SI

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WHEREAS, the last day to exchange expert witness reports, by counsel agreement,
was October 9, 2015 and last day to exchange rebuttal expert witness reports was October
26, 2015;

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WHEREAS, the parties’ and their experts have been engaged in negotiations
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regarding additional testing; and,
WHEREAS, the parties’ have scheduled a private mediation for November 17, 2015

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and a settlement conference with Magistrate Judge Laurel Beeler previously set for

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December 3, 2015 and now vacated;

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The parties, by and through their counsel of record, have agreed and therefore
stipulate to request that the:

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Last Day to Designate and Exchange Expert Reports be November 30, 2015;
Last Day to Designate and Exchange Rebuttal Expert Reports be December 18,
2015; and

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Expert Witness Discovery Cutoff be January 18, 2015.

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Respectfully submitted.

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Dated: November 6, 2015

BIRNBERG & ASSOCIATES

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By:

/s/ Cory A. Birnberg
Cory A. Birnberg
Attorneys for Plaintiff, MICHAEL HERRERA

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Dated: November 6, 2015

GIBSON ROBB & LINDH
By:

/s/ Jennifer Tomlin Sanchez
Jennifer Tomlin Sanchez
Attorneys for Defendant & Third-Party Plaintiff,
NEFF RENTAL, LLC

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BIRNBERG &
ASSOCIATES
1083 MISSION STREET
Third Floor
SAN FRANCISCO
CA, 94103
TEL [phone]
FAX [phone]

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(next page)

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT WITNESS DISCLOSURES
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Case No. Civ-14-2295 SI

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Dated: November 6, 2015

COX, WOOTTON, LERNER, ET AL.
By:

/s/ Max L. Kelley
Max L. Kelley
Attorneys for Intervening Plaintiff &
Third-Party Defendant, PORTS INSURANCE CO.,
and MARINE TERMINALS CORP., d.b.a. PORTS AMERICA

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[PROPOSED] ORDER

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APPROVED AND SO ORDERED.

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Dated: November ___, 2015

By: ________________________________
The Honorable Susan Illston
United States District Court Judge
Northern District of California

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BIRNBERG &
ASSOCIATES
1083 MISSION STREET
Third Floor
SAN FRANCISCO
CA, 94103
TEL [phone]
FAX [phone]

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT WITNESS DISCLOSURES
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Case No. Civ-14-2295 SI