Gipson v. Dewalt Industrial Tool Co., et al

Filing 28

STIPULATION AND ORDER FOR EXPERT DISCLOSURES AND FACT DISCOVERY CUT-OFF. Fact Discovery due by 4/14/2017. Expert Discovery due by 5/28/2017. Signed by Judge Laurel Beeler on 02/09/2017. (tmiS, COURT STAFF) (Filed on 2/9/2017)

1 Kevin R. Crisp (Bar No. 97504)
[e-mail]
2 Renata L. Hoddinott (Bar No. 251714)
[e-mail]
3 HAIGHT BROWN & BONESTEEL LLP
Three Embarcadero Center, Suite 200
4 San Francisco, California 94111
Telephone: [phone]
5 Facsimile: 415.546.7505
6 Attorneys for Defendants Black & Decker
(U.S.) Inc. erroneously named and served as
7 DeWalt Industrial Tool Co.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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11 TUBO GIPSON,
Plaintiff,

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v.

14 BLACK & DECKER (U.S.) INC.,

Case No. 3:16-CV-03114-LB
Assigned to: Hon. Laurel Beeler
STIPULATION AND [PROPOSED]
ORDER FOR EXPERT
DISCLOSURES AND FACT
DISCOVERY CUT-OFF

Defendant.

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Trial Date:

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September 25, 2017

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IT IS HEREBY STIPULATED by and between Plaintiff TUBO GIPSON
(“Plaintiff”), and Defendant BLACK & DECKER (U.S.) INC. (“Black & Decker”) by and
through their respective attorneys of record:
WHEREAS:
On September 15, 2016, the parties participated in an Initial Case

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Management Conference before Magistrate Beeler.

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On September 19, 2016, the Court issued a Case Management and Pre-Trial

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Order providing fact and expert discovery dates.

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The Case Management and Pre-Trial Order also provided for an ADR

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completion date of December 14, 2016.

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SW05-0000390
12193073.1

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Case No. 3:16-CV-03114-LB
STIPULATION AND [PROPOSED] ORDER FOR
EXPERT DISCLOSURES AND FACT
DISCOVERY CUT-OFF

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The parties previously stipulated to and participated in the ENE on January

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12, 2017.

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Black & Decker was limited to one deposition prior to the ENE.

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In light of the January 12, 2017 ENE the parties are unable to complete fact

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and expert discovery based on the schedule set forth in the Case

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Management and Pre-Trial Order.

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The parties stipulate as follows:

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1.

Initial expert disclosures will be exchanged by both parties on April 14,
2017.

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2.

Fact discovery cut-off is continued to April 14, 2017.

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3.

Rebuttal expert disclosures will be exchanged by both parties on April 28,
2017.

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4.

Expert discovery completion is continued to May 28, 2017.

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IT IS SO STIPULATED.

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18 Dated: February 8, 2017

LAW OFFICE OF NIKOLAUS W. REED

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By:

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/s
Nikolaus W. Reed
Attorneys for Plaintiff TUBO GIPSON

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SW05-0000390
12193073.1

2

Case No. 3:16-CV-03114-LB
STIPULATION AND [PROPOSED] ORDER FOR
EXPERT DISCLOSURES AND FACT
DISCOVERY CUT-OFF

1 Dated: February 8, 2017

HAIGHT BROWN & BONESTEEL LLP

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By:

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/s
Kevin R. Crisp
Renata L. Hoddinott
Attorneys for Defendants Black & Decker
(U.S.) Inc. erroneously named and served as
DeWalt Industrial Tool Co.

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ORDER
Based on the stipulation of the parties, IT IS HEREBY ORDERED the Case
Management and Pre-Trial Order is amended as follows:
1.

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2017.
2.

Fact discovery cut-off is continued to April 14, 2017.

3.

Rebuttal expert disclosures will be exchanged by both parties on April 28,

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Initial expert disclosures will be exchanged by both parties on April 14,

2017.
4.

Expert discovery completion is continued to May 28, 2017.

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IT IS SO ORDERED.

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02/09
___________, 2017

__________________________

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Judge of the District Court

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SW05-0000390
12193073.1

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Case No. 3:16-CV-03114-LB
STIPULATION AND [PROPOSED] ORDER FOR
EXPERT DISCLOSURES AND FACT
DISCOVERY CUT-OFF