Chen v. BMW of North America, LLC

Filing 23

ORDER re 22 Stipulation Extending Expert Discovery Dates AS MODIFIED. Expert Witness List due by 3/1/2012. Rebuttal expert disclosures 3/15/2012. Expert discovery due 3/29/2012. Signed by Magistrate Judge Donna M. Ryu on 12/19/2011. (dmrlc1, COURT STAFF) (Filed on 12/19/2011)

1 ROGER S. RAPHAEL, SB# 111946
E-Mail: [e-mail]
2 WILLIAM BURANICH, SB# 144650
E-Mail: [e-mail]
3 LEWIS BRISBOIS BISGAARD & SMITH LLP
One Sansome Street, Suite 1400
4 San Francisco, California 94104
Telephone: [phone]
5 Facsimile: 415.434.0882
6 Attorneys for Defendant BMW OF NORTH
AMERICA, LLC
7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

10
11 GANG CHEN,
Plaintiff,

12
13

v.

14 BMW OF NORTH AMERICA, LLC, AND
DOES 1 THROUGH DOE 10, INCLUSIVE,
15
Defendants.
16
17

CASE NO. CV11 1668 DMR
Action Filed: April 6, 2011
STIPULATION AND ORDER TO
EXTEND EXPERT DISCOVERY DATES
AS MODIFIED
Trial date: May 14, 2012

Plaintiff GANG CHEN ("CHEN") and defendant BMW of NORTH AMERICA, LLC “(BMW

18 NA”) through their respective attorneys of record, hereby stipulate as follows:
19

WHEREAS, at the initial Case Management Conference the Court set various dates relating to

20 expert disclosure, rebuttal expert disclosure and expert discovery completion;
21

WHEREAS, out of necessity the parties have previously obtained from the court an extension

22 of the non-expert discovery cut-off until March 1, 2012;
23

WHEREAS, such order should have also addressed expert discovery dates to coincide with the

24 new non-expert discovery date, allowing regular discovery to be completed before expert discovery
25 commences;
26

WHEREAS, CHEN and BMW NA request that this Court continue the date for expert

27 disclosures to March 1, 2012, the date for rebuttal expert disclosures to March 15, 2012 and the expert

LEWI
S

BRISBO
IS

28 discovery completion date to March 29, 2012.
4822-0185-8062.1

CV11 1668 DMR
STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DATES

1

THEREFORE IT IS STIPULATED by and between CHEN and BMW NA that the deadlines

2 associated with expert discovery are extended as follows: the date for expert disclosures will be
3 March 1, 2012, the date for rebuttal expert disclosures will be March 15, 2012 and the expert
4 discovery completion date will be March 29, 2012.
5

This Stipulation may be signed in counter-parts, each counter-part having the same force and

6 effect as originals, and facsimile signatures shall be deemed to have the same force as originals.
7
8 DATED:

December 15, 2011

THE BICKEL LAW FIRM, INC.

9
By:

/s/ Michael Devlin
Michael Devlin, Esq.
Attorneys for Plaintiff GANG CHEN

10
11
12 DATED:

December 15, 2011

LEWIS BRISBOIS BISGAARD & SMITH LLP

13
By:

/s/ William P. Buranich
Roger S. Raphael, Esq.
William P. Buranich, Esq.
Attorneys for Defendant BMW OF NORTH
AMERICA, LLC

14
15
16
17
18

ORDER
IT IS ORDERED, based upon the stipulation of the parties that the date for expert disclosures

19 is extended from December 27, 2011 to March 1, 2012; the date for rebuttal expert disclosures is
20 extended from January 10, 2012 to March 15, 2012; and the date for completion of expert discovery is
21 extended from January 24, 2012 to March 29, 2012. All non-discovery and non-mediation case
22 management dates set in the court’s July 18, 2011 Order (Docket No. 15) remain in effect.
23
24 DATED: December 19, 2011
25
26

By__________________________________
DONNA M. RYU
Magistrate Judge of the
United States District Court

27

LEWI
S

BRISBO
IS

28
4822-0185-8062.1

2
STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DATES

CV11 1668 DMR