Matsumoto-Herera v. Continental Casualty Company

Filing 27

Order by Hon. Vince Chhabria granting 25 Stipulation Continuing Discovery Cutoff.(knm, COURT STAFF) (Filed on 5/15/2015)

1
2
3
4
5

CLARICE C. LIU (SBN 160555)
[e-mail]
LIU EMPLOYMENT LAW FIRM
One Sansome Street, 35th Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
GINGER MATSUMOTO-HERRERA

6
7
8
9
10

12
SAN FRANCISCO, CA 94104
[phone]

ONE SANSOME STREET, SUITE 3500

LIU EMPLOYMENT LAW FIRM

11

Camille A. Olson, SBN 111919
Richard B. Lapp, SBN 271052
Cassandra H. Carroll, SBN 209123
SEYFARTH SHAW, LLP
560 Mission St., Suite 3100
San Francisco, CA 94105-2930
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
[e-mail]
[e-mail]

13

Attorneys for Defendant
CONTINENTAL CASUALTY COMPANY

14
15
16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA

18
19

GINGER MATSUMOTO-HERRERA,

20

Plaintiff,

21
22

CASE NO. 14-cv-03626-VC
STIPULATION AND [PROPOSED]
ORDER CONTINUING DISCOVERY
CUTOFF DATE

v.
CONTINENTAL CASUALTY COMPANY,
and DOES 1 through 100, inclusive,

23
24

Defendants.

25
26
27
28
1
STIPULATION AND [PROPOSED] ORDER CONTINUING DISCOVERY CUTOFF DATE

1
2

Whereas, the Court’s current Minute Order entered November 18, 2014 sets the close of
regular discovery for June 17, 2015 (Docket #18);
Whereas, due to the voluminous electronic documents involved in discovery production as

3
4
5
6

well as the number of witness depositions in this matter (three in Chicago, Illinois, and one in
Minneapolis, Minnesota), Plaintiff Ginger Matsumoto-Herrera and Defendant Continental Casualty
Company (the “Parties”) anticipate that additional time will be required for the completion of the

7
8

depositions in this matter;
Whereas, the Court’s current Minute Order does not expressly set forth a deadline for

9

desire to set a fixed expert discovery schedule;

12
SAN FRANCISCO, CA 94104
[phone]

ONE SANSOME STREET, SUITE 3500

expert disclosures, supplemental expert disclosures, or the close of expert discovery, and the parties

11
LIU EMPLOYMENT LAW FIRM

10

Whereas, the parties have agreed to continue the discovery deadline in this matter for

13

sixteen (16) days until July 3, 2015 to address these matters, to exchange expert disclosures on

14

July 15 and rebuttal expert disclosures on July 30, and that the expert discovery deadline in this

15

matter shall be August 21, 2015, and agree that they can do so without disturbing any other date or

16

deadline in the Court’s November 18, 2014 Minute Order.

17

Therefore, the Parties stipulate as follows:

18

STIPULATION

19

The Parties, by and through their counsel duly authorized, hereby stipulate to and request

20

that the Court enter an Order continuing the discovery cutoff date until July 3, 2015, to exchange

21

expert disclosures on July 15, 2015 and rebuttal expert disclosures on July 30, 2015 and that the

22

expert discovery deadline in this matter shall be August 21, 2015.

23

//

24

//

25

//

26

//

27

//

28

2
STIPULATION AND [PROPOSED] ORDER CONTINUING DISCOVERY CUTOFF DATE

Respectfully Submitted By,

1
2

DATED: May 12, 2015

LIU EMPLOYMENT LAW FIRM

3
4

By:

/s/ Clarice C. Liu
Clarice C. Liu
Attorneys for Plaintiff
GINGER MATSUMOTO-HERRERA

5
6
7
8

DATED: May 12, 2015

SEYFARTH SHAW LLP

9
By:

/s/ Cassandra H. Carroll
Camille A. Olson
Richard B. Lapp
Cassandra H. Carroll
Attorneys for Defendant
CONTINENTAL CASUALTY COMPANY

10

12
SAN FRANCISCO, CA 94104
[phone]

ONE SANSOME STREET, SUITE 3500

LIU EMPLOYMENT LAW FIRM

11

13
14
15
16
17
18
19

[PROPOSED] ORDER
GOOD CAUSE APPEARING, the Stipulation of the Parties is hereby GRANTED. The
November 18, 2014 Minute Order is hereby modified continuing the discovery cutoff date until
July 3, 2015, the exchange expert disclosures on July 15, 2015 and rebuttal expert disclosures on
July 30, 2015 and that the expert discovery deadline in this matter shall be August 21, 2015.
IT IS SO ORDERED.

20
21

Dated: May 15, 2015
________
The Hon. Vince Chhabria
Judge of the United States District Court

22
23
24
25
26
27
28

3
STIPULATION AND [PROPOSED] ORDER CONTINUING DISCOVERY CUTOFF DATE