Wells v. Penske Truck Leasing Corporation et al

Filing 33

ORDER Granting 32 Stipulation REQUEST TO EXTEND DEADLINES. Case Management Statement due by 7/7/2011. Further Case Management Conference set for 7/14/2011 02:00 PM. Motion Hearing set for 7/14/2011 02:00 PM before Hon. Claudia Wilken. Signed by Judge Claudia Wilken on 4/22/2011. (ndr, COURT STAFF) (Filed on 4/22/2011)

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JONATHAN ALLAN KLEIN (SBN 162071)
STACEY A. ZARTLER (SBN 160859)
KELLY, HOCKEL & KLEIN P.C.
One Sansome Street, Suite 1800
San Francisco, CA 94104
Tel.: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
PENSKE TRUCK LEASING CO., L.P., erroneously sued as
PENSKE TRUCK LEASING CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MICHAEL WELLS,

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Plaintiff,
vs.
PENSKE TRUCK LEASING
CORPORATION; PENSKE TRUCK
LEASING, LLC; and DOES 1-25,
Defendants.

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Case No: C-10-3926 CW (JL)
STIPULATION AND JOINT REQUEST TO
EXTEND DEADLINES
Trial Date: October 3, 2011

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Defendant Penske Truck Leasing Co., L.P., erroneously sued as Penske Truck Leasing
Corporation, and Plaintiff Michael Wells, by and through their respective counsel, hereby
stipulate and request that the Court continue the discovery and related deadlines in this matter
by 25-45 days, as set forth fully herein. The parties wish to leave the current trial date of
October 3, 2011, the September 20, 2011 pre-trial conference, and all associated trial-related
filing deadlines, on calendar as scheduled.
Good cause exists for extending the discovery deadlines inasmuch as lead counsel for
Defendant is leaving Kelly, Hockel & Klein, P.C. and the parties have been unable to complete
necessary discovery due to the trial schedules of both Plaintiff’s counsel and defense counsel.
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STIPULATION AND JOINT REQUEST TO EXTEND
DEADLINES

Case No. C 10-3926 CW (JL)

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This is the first request for a continuance of any dates in this matter. The current dates
and proposed dates on calendar are as follows:
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Current:
Proposed:

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2.

3.

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4.

June 2, 2011
July 12, 2011

Expert Disclosures:
Current:
Proposed:

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May 16, 2011
June 30, 2011

Status Conference and Dispositive Motion:
Current:
Proposed:

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Non-Expert Discovery Cut-Off:

July 5, 2011
August 2, 2011

Expert Discovery Cut-Off:
Current:
Proposed:

August 5, 2011
August 23, 2011

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DATED: April _15_, 2011

KELLY, HOCKEL & KLEIN P.C.

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___________/S/______________________
JONATHAN ALLAN KLEIN
STACEY A. ZARTLER
Attorneys for Defendant
PENSKE TRUCK LEASING CO., L.P.

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DATED: April _21__, 2011

ROUDA, FEDER, TIETJEN & MCGUINN

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___________/S/______________________
JUNE BASHANT
Attorneys for Plaintiff
MICHAEL WELLS

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STIPULATION AND JOINT REQUEST TO EXTEND
DEADLINES

Case No. C 10-3926 CW (JL)

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DATED: April ___, 2011

LAW OFFICE OF STEPHEN M. MURPHY

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___________________________________
STEPHEN M. MURPHY
Attorneys for Plaintiff
MICHAEL WELLS

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ORDER

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BASED ON THE FOREGOING, IT IS HEREBY ORDERED THAT THE
FOLLOWING DEADLINES BE RESCHEDULED AS FOLLOWS:

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1.

Non-Expert Discovery Cut-Off:

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2.

Further Case Management and Dispositive Motion Hearing:July 14, 2011

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June 30, 2011

The motion filing deadline will run back from the July 14 date.

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3.

Expert Disclosures:

August 2, 2011

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4.

Expert Discovery Cut-Off:

August 23, 2011

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ALL OTHER DATES WILL REMAIN ON CALENDAR AS SCHEDULED.

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4/22/2011
DATED: _______

____________________________________
The Honorable Claudia Wilken

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STIPULATION AND JOINT REQUEST TO EXTEND
DEADLINES

Case No. C 10-3926 CW (JL)