United Energy Trading, LLC v. Pacific Gas & Electric Co. et al

Filing 135

STIPULATION AND ORDER TO EXTEND TIME TO PRODUCE EXPERT AND EXPERT REBUTTAL DISCLOSURES. Signed by Judge Richard Seeborg on 12/21/16. (cl, COURT STAFF) (Filed on 12/21/2016)

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HOLLAND & KNIGHT LLP
Thomas D. Leland (Pro Hac)
Leah E. Capritta (Pro Hac)
633 Seventeenth Street, Suite 2300
Denver, Colorado 80202
Telephone [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]

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Charles L. Coleman III (65496)
50 California Street, Suite 2800
San Francisco, CA 94111
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
UNITED ENERGY TRADING, LLC

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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UNITED ENERGY TRADING, LLC,

CASE NO. 3:15-CV-2383-RS

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Plaintiff,
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vs.
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PACIFIC GAS AND ELECTRIC
COMPANY, a California corporation;
ALBERT TORRES, an individual; BILL
CHEN, an individual; TANISHA
ROBINSON, an individual,

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Defendants.
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[PROPOSED] ORDER GRANTING
STIPULATED REQUEST TO EXTEND
TIME TO PRODUCE EXPERT AND
EXPERT REBUTTAL DISCLOSURES
PURSUANT TO CIVIL LOCAL RULES 61(b), 6-2, 7-12
Action Filed:
May 28, 2015
Current Deadlines: Jan. 9, 2017 and
Apr. 18, 2017
New Deadlines:
Apr. 10, 2017 and
June 19, 2017

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[Stipulation and Declaration of Leah E.
Capritta in support thereof filed concurrently
herewith]

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Case No. 3:15-CV-2383-RS

[PROPOSED] ORDER GRANTING STIPULATED
REQUEST TO EXTEND TIME

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[PROPOSED] ORDER REGARDING STIPULATED REQUEST TO EXTEND TIME

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The Stipulated Request to Extend Time to Produce Expert and Expert Rebuttal

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Disclosures, Pursuant to Civil Local Rules 6-1(b), 6-2, 7-12 (“Stipulated Request”), agreed to by

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Plaintiff United Energy Trading, LLC (“UET”) and Defendants Pacific Gas and Electric

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Company (“PG&E”), Albert Torres, Bill Chen and Tanisha Robinson (collectively, the

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“Individual Defendants,” and together with PG&E, the “Defendants”), was submitted for Court

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approval on December 20, 2016. Having considered the Stipulated Request, and all other

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pleadings and papers on file in this Action, the Court rules as follows:

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WHEREAS plaintiff, United Energy Trading, LLC (“UET”), filed this action on May 28,
2015;

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WHEREAS, on May 13, 2016, UET filed its Second Amended Complaint;

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WHEREAS, on August 25, 2016, Defendants Pacific Gas & Electric Company

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(“PG&E”), Albert Torres, William Chen and Tanisha Robinson (collectively, the “Individual

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Defendants,” and together with PG&E, the “Defendants”) filed an Answer to UET’s Second

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Amended Complaint;

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WHEREAS, the parties previously stipulated and requested that the Court extend the

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deadlines for expert discovery such that the parties would have until January 9, 2017 to file

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Expert Disclosures and until April 18, 2017 to file Rebuttal Expert Disclosures (Dkt. 115);

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WHEREAS, the Court granted that request (Dkt. 116);

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WHEREAS, discovery is continuing and the parties are continuing to produce documents

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in response to written Requests;
WHEREAS, multiple discovery disputes regarding the timing and scope of production of
additional documents by PG&E are pending before Magistrate Judge Kim;
WHEREAS, the enlargement sought by this Stipulated Request will conserve resources

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for all parties because it will ensure that the parties’ experts have adequate time to limit their

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review to the information relevant to and prepare opinions on the live claims;

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WHEREAS, all parties have agreed that they shall have until April 10, 2017 to file Expert
Disclosures and until June 19, 2017 to file Rebuttal Expert Disclosures;
Case No. 3:15-CV-2383-RS

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[PROPOSED] ORDER GRANTING STIPULATED
REQUEST TO EXTEND TIME

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WHEREAS, good cause for this extension exists given the progress of the case to date;

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WHEREAS, all parties have agreed that the current expert disclosure schedule required by

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the Scheduling Order should be enlarged as follows:

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Pleading

Standard Schedule

Stipulated Enlargement

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Expert Disclosure Deadline

January 9, 2017

April 10, 2017

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Rebuttal Expert Disclosure Deadline

April 18, 2017

June 19, 2017

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WHEREAS, the stipulated enlargements are sought in advance of the expiration of any
related disclosure deadline;
WHEREAS, the stipulated disclosure enlargements do not affect any other existing dates
set forth in the Scheduling Order;
WHEREAS, none of the extensions sought by the Stipulated Request prejudice the parties
or the Court;

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Good cause appearing therefor, IT IS HEREBY ORDERED THAT:

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1. The date for the Parties to disclose Experts is extended from January 9, 2017 through

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and including April 10, 2017;
2. The date for the Parties to disclose Rebuttal Experts is extended from April 18, 2017
through and including June 19, 2017.

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December
SO ORDERED this ______ day of _____, 2016.
21st

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By:
The Honorable Richard G. Seeborg
United States District Court Judge

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Case No. 3:15-CV-2383-RS

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STIPULATED REQUEST TO EXTEND TIME