Sran v. Regents of the University of California

Filing 40

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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1 2 3 4 5 6 7 8 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 9 UNITED STATE DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO 11 KULGINDER SRAN, 12 Plaintiff, 13 14 15 16 vs. REGENTS OF THE UNIVERSITY OF CALIFORNIA 17 Defendants. 18 ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C-15-4471-JST STIPULATION AND [PROPOSED] ORDER CONTINUING EXPERT REBUTTAL AND EXPERT DISCOVERY DEADLINES Complaint Filed: September 30, 2015 19 RECITALS 20 21 WHEREAS the parties have exchanged written discovery and substantial documents in 22 the case, conducted numerous witness depositions, and otherwise diligently worked together to 23 move the case forward; 24 WHEREAS the current deadline to disclose rebuttal expert witnesses is May 1, 2017; 25 WHEREAS the current expert discovery cutoff is May 15, 2017; 26 WHEREAS the parties are in the process of completing substantial expert witness 27 28 discovery; WHEREAS both parties anticipate disclosing rebuttal expert witnesses; -1- STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST MAST 1 WHEREAS both parties anticipate taking multiple expert witness depositions; 2 WHEREAS the parties have identified an issue impacting the scope of testimony to be 3 provided by expert witnesses relating to the issue of damages and therefore require additional 4 time to meet and confer about the issue so as to reach a possible agreement; 5 6 WHEREAS the parties need additional time to meaningfully conduct expert witness discovery thereafter; 7 WHEREAS the parties are still in active settlement negotiations with Justice Lambden of 8 ADR Services following mediation on November 15, 2016, and would like to continue 9 participating in settlement discussions; 10 WHEREAS the parties respectfully request that the Court continue the current expert Gordon & Rees LLP 275 Battery Street, Suite 2000 San Francisco, CA 94111 11 discovery deadlines as outlined by the parties below, or as soon thereafter as the Court is 12 available. 13 14 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. 15 16 WHEREAS, alternatively, the parties request a CMC to further discuss these issues with the Court. 17 STIPULATION 18 19 THEREFORE, IT IS HEREBY STIPULATED THAT the expert rebuttal and expert discovery cutoff deadlines are continued as follows: 20 21 22 23 Event Current Date Proposed Date Expert rebuttal Expert Discovery Cutoff May 1, 2017 May 15, 2017 June 16, 2017 June 30, 2017 24 25 26 27 28 /// -2- STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST 1 Dated: April 20, 2017 GORDON & REES SCULLY MANSUKHANI LLP 2 3 By: /s/ Jennifer M. Lynch JENNIFER M. LYNCH Attorney for Defendant REGENTS OF THE UNIVERSITY OF CALIFORNIA 4 5 6 Dated: April 20, 2017 LEIGH LAW GROUP 7 By: /s/ Jay Jambeck Jay Jambeck Attorney for Plaintiff KULGINDER SRAN 8 9 10 [PROPOSED] ORDER Gordon & Rees LLP 275 Battery Street, Suite 2000 San Francisco, CA 94111 11 12 According to the parties’ stipulation, and good cause appearing, it is hereby ordered that 13 the expert rebuttal and expert discovery cutoff deadlines of this matter are hereby continued as 14 follows: 15 16 17 Event Expert rebuttal Expert Discovery Cutoff Current Date May 1, 2017 May 15, 2017 Proposed Date June 16, 2017 June 30, 2017 18 19 20 21 IT IS SO ORDERED. Dated: April 25, 2017 _____________________________________ Hon. Jon S. Tigar 22 23 24 25 26 27 28 UCR/1112749/32581486v.1 -3- STIPULATION AND [PROPOSED] ORDER – Case No. C-15-4471-JST

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