Sran v. Regents of the University of California
Filing
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STIPULATION AND ORDER re 39 STIPULATION WITH PROPOSED ORDER to Continue Expert Rebuttal and Expert Discovery Deadlines filed by Regents of the University of California. Expert Rebuttals due 6/16/2017. Expert Discovery Cutoff 6/30/2017. Signed by Judge Jon S. Tigar on April 25, 2017. (wsn, COURT STAFF) (Filed on 4/26/2017)
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MICHAEL D. BRUNO (SBN: 166805)
mbruno@gordonrees.com
ALYSON S. CABRERA (SBN 222717)
acabrera@gordonrees.com
JENNIFER M. LYNCH (SBN 272976)
jlynch@gordonrees.com
GORDON & REES
SCULLY MANSUKHANI LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: (415) 986-5900
Facsimile: (415) 986-8054
Attorneys for Defendant
REGENTS OF THE UNIVERSITY OF CALIFORNIA
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UNITED STATE DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO
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KULGINDER SRAN,
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Plaintiff,
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vs.
REGENTS OF THE UNIVERSITY OF
CALIFORNIA
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Defendants.
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Case No. C-15-4471-JST
STIPULATION AND [PROPOSED]
ORDER CONTINUING EXPERT
REBUTTAL AND EXPERT
DISCOVERY DEADLINES
Complaint Filed: September 30, 2015
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RECITALS
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WHEREAS the parties have exchanged written discovery and substantial documents in
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the case, conducted numerous witness depositions, and otherwise diligently worked together to
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move the case forward;
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WHEREAS the current deadline to disclose rebuttal expert witnesses is May 1, 2017;
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WHEREAS the current expert discovery cutoff is May 15, 2017;
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WHEREAS the parties are in the process of completing substantial expert witness
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discovery;
WHEREAS both parties anticipate disclosing rebuttal expert witnesses;
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STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST
MAST
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WHEREAS both parties anticipate taking multiple expert witness depositions;
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WHEREAS the parties have identified an issue impacting the scope of testimony to be
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provided by expert witnesses relating to the issue of damages and therefore require additional
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time to meet and confer about the issue so as to reach a possible agreement;
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WHEREAS the parties need additional time to meaningfully conduct expert witness
discovery thereafter;
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WHEREAS the parties are still in active settlement negotiations with Justice Lambden of
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ADR Services following mediation on November 15, 2016, and would like to continue
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participating in settlement discussions;
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WHEREAS the parties respectfully request that the Court continue the current expert
Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
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discovery deadlines as outlined by the parties below, or as soon thereafter as the Court is
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available.
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WHEREAS the continuance of the deadlines as proposed below will not impact the
August 14, 2017 trial date, or any other deadlines set by this Court.
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WHEREAS, alternatively, the parties request a CMC to further discuss these issues with
the Court.
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STIPULATION
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THEREFORE, IT IS HEREBY STIPULATED THAT the expert rebuttal and expert
discovery cutoff deadlines are continued as follows:
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Event
Current Date
Proposed Date
Expert rebuttal
Expert Discovery Cutoff
May 1, 2017
May 15, 2017
June 16, 2017
June 30, 2017
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///
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STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST
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Dated: April 20, 2017
GORDON & REES
SCULLY MANSUKHANI LLP
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By:
/s/ Jennifer M. Lynch
JENNIFER M. LYNCH
Attorney for Defendant
REGENTS OF THE UNIVERSITY OF
CALIFORNIA
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Dated: April 20, 2017
LEIGH LAW GROUP
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By:
/s/ Jay Jambeck
Jay Jambeck
Attorney for Plaintiff
KULGINDER SRAN
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[PROPOSED] ORDER
Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
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According to the parties’ stipulation, and good cause appearing, it is hereby ordered that
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the expert rebuttal and expert discovery cutoff deadlines of this matter are hereby continued as
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follows:
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Event
Expert rebuttal
Expert Discovery Cutoff
Current Date
May 1, 2017
May 15, 2017
Proposed Date
June 16, 2017
June 30, 2017
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IT IS SO ORDERED.
Dated: April 25, 2017
_____________________________________
Hon. Jon S. Tigar
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UCR/1112749/32581486v.1
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STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST
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