Macdonald et al v. Wells Fargo Bank N.A

Filing 71

ORDER by Judge Haywood S. Gilliam, Jr. Granting 70 Stipulation to Continue Expert Discovery Deadlines. (ndrS, COURT STAFF) (Filed on 1/30/2017)

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MARK D. LONERGAN (State Bar No. 143622)
THOMAS N. ABBOTT (State Bar No. 245568)
JASON M. JULIAN (State Bar No. 215342)
[e-mail]
SEVERSON & WERSON
A Professional Corporation
One Embarcadero Center, Suite 2600
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
WELLS FARGO BANK, N.A.
MATHEW D. MELLEN (Bar No. 233350)
SARAH SHAPERO (Bar No. 281748)
MELLEN LAW FIRM
One Embarcadero Center, Fifth Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs,
BRET MACDONALD and AMALIA MACDONALD

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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BRET MACDONALD, an individual; and
AMALIA MACDONALD, an individual,

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JOINT STIPULATION TO CONTINUE
EXPERT DISCOVERY CUT-OFF
DEADLINE; [PROPOSED] ORDER

Plaintiffs,

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Case No.: 3:14-CV-04970-HSG

vs.
WELLS FARGO BANK, N.A. and
DOES 1 through 50, inclusive,

Action Filed:
Trial Date:

Defendants.

November 10, 2014
May 1, 2016

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55002.0454/10176046.1

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JOINT STIPULATION AND PROPOSED ORDER TO CONTINUE EXPERT DISCOVERY CUT-OFF DEADLINE

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Pursuant to the Civil Local Rules of the United States District Court for the Northern
District of California, the parties, Plaintiffs BRETT MACDONALD and AMALIA
MACDONALD (“Plaintiffs”), and Defendant WELLS FARGO BANK, N.A. (“Wells Fargo”),
through their counsel of record, hereby stipulate to the following:
WHEREAS, on November 10 2014, Plaintiff filed her Complaint in the above-captioned
court against Defendants;
WHEREAS, on April 12, 2016, the Court issued a Scheduling Order, setting Expert
Discovery Cutoff for October 25, 2016;
WHEREAS, the Expert Discovery Cut-off deadline has been continued by the Court,
following the parties stipulations, to January 27, 2017;
WHEREAS, Plaintiffs submitted their Initial Expert Disclosure on December 9, 2016,
disclosing the intent to use an expert to testify at trial on Plaintiffs’ behalf;
WHEREAS, Defendant designated a Rebuttal Expert on December 23, 2016;
WHEREAS, the medical experts that have been designated by both parties have schedules
that have made it difficult to obtain deposition dates that work for all parties;
WHEREAS, Defendant’s deposition of Plaintiff’s Expert is currently scheduled for
January 27, 2017 and Plaintiffs’ deposition of Defendant’s Expert is currently scheduled for
February 20, 2017;
WHEREAS, the Parties request that the deadline to conduct all Expert Discovery be
extended to February 20, 2017;
WHEREAS, no other deadlines in this matter will be affected by the requested
continuance.

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STIPULATION
The parties stipulate to and request continuance of the Expert Discovery Cut-off Deadline
to February 20, 2017.

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55002.0454/10176046.1

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JOINT STIPULATION AND PROPOSED ORDER TO CONTINUE EXPERT DISCOVERY CUT-OFF DEADLINE

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Respectfully Submitted,

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Dated: January 24, 2017

SEVERSON & WERSON

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By:

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_/s/ Jason M. Julian________
Jason M. Julian, Esq.
Attorney for Defendant
WELLS FARGO BANK, N.A.

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Dated: January 24, 2017

MELLEN LAW FIRM

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By:

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_/s/ Sarah Shapero_________
Sarah Shapero, Esq.
Attorney for Plaintiffs
BRETT MACDONALD and AMALIA
MACDONALD

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55002.0454/10176046.1

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JOINT STIPULATION AND PROPOSED ORDER TO CONTINUE EXPERT DISCOVERY CUT-OFF DEADLINE

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ORDER
This Court, having received and reviewed the stipulation of the parties referenced
immediately above, and finding good cause therefore, pursuant to the stipulation of the parties;
The expert discovery cut-off deadline is continued to February 20, 2017.
IT IS SO ORDERED.

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Dated: _____________, 2017
January 30
________________________________________
Honorable Haywood S. Gilliam, Jr.

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55002.0454/10176046.1

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JOINT STIPULATION AND PROPOSED ORDER TO CONTINUE EXPERT DISCOVERY CUT-OFF DEADLINE