Richard Terry v. Hoovestol, Inc.

Filing 39

STIPULATION AND ORDER re 38 STIPULATION WITH PROPOSED ORDER Extending The Parties Class Certification Related Expert Discovery Cut-Off By Twenty-One (21) Days filed by Richard Terry. Signed by Judge Jon S. Tigar on December 18, 2017. (wsn, COURT STAFF) (Filed on 12/18/2017)

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William Turley, Esq. (122408)
[e-mail]
David Mara, Esq. (230498)
[e-mail]
Jill Vecchi, Esq. (299333)
[e-mail]
Matthew Crawford, Esq.
[e-mail]
THE TURLEY & MARA LAW FIRM, APLC
7428 Trade Street
San Diego, California 92121
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff RICHARD TERRY
on behalf of himself and all others similarly
situated, and on behalf of the general public
Cathy L. Arias, Esq. (141989)
[e-mail]
Raymond A. Greene, III, Esq. (131510)
[e-mail]
BURNHAM BROWN
P.O. Box 119
Oakland, California 94606
1901 Harrison Street, 14th Floor
Oakland, California 94612
Telephone [phone]
Facsimile [phone]
Attorneys for Defendant
HOOVESTOL, INC.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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RICHARD TERRY, on behalf of himself
and all others similarly situated, and on
behalf of the general public

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Plaintiff,

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v.

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HOOVESTOL, INC., and DOES 1-100

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Case No. 3:16-cv-5183
[Assigned for all purposes to the Honorable Jon
S. Tigar]
STIPULATION AND [PROPOSED] ORDER
EXTENDING THE PARTIES’ CLASS
CERTIFICATION RELATED EXPERT
DISCOVERY CUT-OFF BY TWENTY-ONE
(21) DAYS

Defendants.
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Complaint Filed: July 20, 2016
Removed: September 8, 2016
Trial Date: None Set

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Stipulation and [Proposed] Order Extending the Parties’ Class
Certification Related Expert Discovery Cut-Off by Twenty-One (21) Days

Case No. 3:16-cv-5183

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Plaintiff RICHARD TERRY (“Plaintiff”) and Defendant HOOVESTOL, INC.

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(“Defendant”) (collectively “the Parties”), by and through their respective counsel, hereby jointly

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submit this Stipulation and [Proposed] Order Extending the Parties’ Class-Certification Related

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Expert Discovery Cut-Off by Twenty-One (21) Days, solely to complete the deposition of

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plaintiff’s expert, Kevin Taylor.

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WHEREAS, the Court issued a Scheduling Order on December 21, 2016 setting the
Parties’ class certification related expert discovery cut-off on December 29, 2017;

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WHEREAS, per the Court’s December 21, 2016 Scheduling Order, the Parties exchanged
their class-certification related expert disclosures on November 10, 2017;

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WHEREAS, per the Court’s December 21, 2016 Scheduling Order, the Parties exchanged
their class-certification related rebuttals on December 8, 2017;

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WHEREAS, on December 8, 2017, Defendant noticed the deposition of Plaintiff’s expert,
Kevin Taylor, to take place on December 27, 2017 in Oakland, California;

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WHEREAS, Mr. Taylor is out of town on December 27, 2017 and is not available until
January 8, 2017;

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WHEREAS, the Parties have met and conferred regarding the date of Mr. Taylor’s

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deposition and have agreed to conduct this deposition on a mutually agreeable date sometime

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between January 8, 2018 and January 19, 2018, subject to the Court granting this stipulation, so

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as to not interrupt Mr. Taylor’s vacation plans;

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WHEREAS, extending the class-certification related discovery cut-off will not affect the

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Parties’ class certification filing deadlines;

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Stipulation and [Proposed] Order Extending the Parties’ Class
Certification Related Expert Discovery Cut-Off by Twenty-One (21) Days

Case No. 3:16-cv-5183

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NOW THEREFORE, it is stipulated by and between Plaintiff and Defendant that the class-

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certification related expert discovery cut-off be continued by twenty-one (21) days from

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December 29, 2017 to January 19, 2018, solely to complete the deposition of plaintiff’s expert,

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Kevin Taylor, subject to the Court’s approval.

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Dated: December 18, 2017

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THE TURLEY & MARA LAW FIRM, APLC
/s/ Jill Vecchi
William Turley, Esq.
David Mara, Esq.
Jill Vecchi, Esq.
Representing Plaintiff RICHARD TERRY on
behalf of himself and all others similarly situated,
and on behalf of the general public

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Dated: December 18, 2017

BURNHAM BROWN

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/s/ Raymond Greene (authorized on 12/18/17)
Cathy L. Arias, Esq.
Raymond A. Greene, III, Esq.
Representing Defendant HOOVESTOL, INC.

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Stipulation and [Proposed] Order Extending the Parties’ Class
Certification Related Expert Discovery Cut-Off by Twenty-One (21) Days

Case No. 3:16-cv-5183

[PROPOSED] ORDER
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Based upon the stipulation of the parties, and good cause having been shown, the Court

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hereby continues the Parties’ class-certification related expert discovery cut-off by twenty-one

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(21) days from December 29, 2017 to January 19, 2018, solely to complete the deposition of

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plaintiff’s expert, Kevin Taylor. All other dates in the Court’s December 21, 2016 Scheduling

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Order remain the same.

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IT IS SO ORDERED.
Dated: December 18, 2017

___________________________________
HONORABLE JON S. TIGAR
UNITED STATES DISTRICT COURT

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Stipulation and [Proposed] Order Extending the Parties’ Class
Certification Related Expert Discovery Cut-Off by Twenty-One (21) Days

Case No. 3:16-cv-5183