Californians for Alternatives to Toxics v. Schneider Dock & Intermodal Facility, Inc. et al

Filing 66

STIPULATION AND ORDER re 65 STIPULATION WITH PROPOSED ORDER to Continue Expert Disclosure Deadline by Seven Days to November 2, 2018 filed by Schneider Dock Industrial Park, LLC, Ryan Schneider, David Schneider, Schneider Dock & Intermodal Facility, Inc. Expert Disclosures due by 11/2/2018. Signed by Judge Jon S. Tigar on October 25, 2018. (wsn, COURT STAFF) (Filed on 10/25/2018)

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THERESE Y. CANNATA (SBN 88032)
MARK P. FICKES (SBN 178570)
QWALYNE E. LAWSON (SBN 304494)
CANNATA, O’TOOLE, FICKES & OLSON LLP
100 Pine Street, Suite 350
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendants
SCHNEIDER DOCK & INTERMODAL
FACILITY, INC., RYAN SCHNEIDER,
DAVID SCHNEIDER and SCHNEIDER
DOCK INDUSTRIAL PARK LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CALIFORNIANS FOR ALTERNATIVES
TO TOXICS,
Plaintiff,

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v.
SCHNEIDER DOCK & INTERMODAL
FACILITY, INC., RYAN SCHNEIDER,
DAVID SCHNEIDER and SCHNEIDER
DOCK INDUSTRIAL PARK LLC

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No. 3:17-cv-05287-JST
STIPULATION TO CONTINUE EXPERT
DISLCOSURE DEADLINE BY SEVEN
DAYS, TO NOVEMBER 2, 2018;
[PROPOSED] ORDER THEREON
_________________________________________
Judge:

Hon. John S. Tigar

Defendants.

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Plaintiff Californians for Alternatives to Toxics (“Plaintiff”), and Defendants Schneider
Dock & Intermodal Facility, Inc., Ryan Schneider, David Schneider, and Schneider Dock
Industrial Park (“Defendants”), by and through their respective counsel, stipulate and agree as

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follows. Plaintiff and Defendants are referred to collectively herein as the “Parties.”
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WHEREAS on January 3, 2018, the Court issued a Scheduling Order, which inter

alia, set October 26, 2018 as the deadline for expert disclosures; (Docket No. 35);
-1STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCLOSURE DEADLINE

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WHEREAS the Parties are engaged in ongoing settlement discussions;

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3.

WHEREAS the Parties desire to avoid the potential costs of preparing expert

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reports should this matter settle before disclosure; and

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4.

WHEREAS the Parties agree to extend the deadline to exchange expert

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disclosures pursuant to Federal Rule of Civil Procedure 26(a)(2) from October 26, 2018 to
November 2, 2018; and,

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5.

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NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and through

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WHEREAS no previous extensions to this deadline have been sought.

the Parties hereto through their undersigned counsel of record, that the Parties shall exchange
their expert disclosures on November 2, 2018.

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Dated: October 24, 2018
CANNATA, O’TOOLE FICKES &
OLSON LLP

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By:

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/s/ Therese Y. Cannata
THERESE CANNATA
Attorneys for Defendants Schneider
Dock & Intermodal Facility, Inc. and
Ryan Schneider

Dated: October 24, 2018

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LAW OFFICES OF ANDREW L.
PACKARD

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By:

/s/ Andrew Packard
ANDREW PACKARD
Attorneys for Plaintiff Californians for
Alternatives to Toxics
(Per Local Rule 5-1(i)(3), Mr.
Packard’s concurrence in the filing of
this document was obtained on
10.24.18.)
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STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCLOSURE DEADLINE

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: October __, 2018

______________________________
JON S. TIGAR
United States District Judge

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-3STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCLOSURE DEADLINE