Alvarez et al v. Lewis

Filing 133

ORDER GRANTING, AS MODIFIED, 130 Stipulation to Extend Expert Discovery Cut-Off. Signed by Judge Jeffrey S. White on September 5, 2014. (jswlc3, COURT STAFF) (Filed on 9/5/2014)

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CHRISTOPHER J. COX (Bar No. 151650)
Email: [e-mail]
BAMBO OBARO (Bar No. 267683)
Email: [e-mail]
JESSICA MOHR (Bar No. 287225)
Email: [e-mail]
WEIL, GOTSHAL & MANGES LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065-1134
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
SERGIO ALVAREZ

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KAMALA D. HARRIS
Attorney General of California
DANIELLE F. O'BANNON
Supervising Deputy Attorney General
BRYAN KAO
Deputy Attorney General
SARA D. VAN LOH (Bar No. 264704)
Deputy Attorney General
Email: [e-mail]
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants SILVEIRA, BARNEBURG,
BRANDON, ROSENBERG, CATE, PIMENTEL, WISE,
JACQUEZ, MCGUYER, AND BRADBURY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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SERGIO ALVAREZ,

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Case No. C 11-2034 JSW (DMR)
Plaintiff,

vs.

STIPULATION AND [PROPOSED]
ORDER TO ENLARGE TIME FOR
EXPERT DISCOVERY CUTOFF

G.D. LEWIS, et al.,
Defendants.

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Dept.:
Courtroom 5 – 2nd Floor
Judge:
Hon. Jeffrey S. White
Trial Date: January 12, 2015

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STIPULATION AND [PROPOSED] ORDER TO ENLARGE
TIME FOR EXPERT DISCOVERY CUTOFF

CASE NO. C 11-2034 JSW (DMR)

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In accordance with Northern District Local Rules 7-12 and 6-2, counsel for both parties

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submit this Stipulation and Proposed Order to extend the expert discovery cutoff, which is set for

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August 27, 2014.

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In support thereof, the parties state:

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The parties have scheduled a second settlement conference in front of Judge Vadas for

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September 12, 2014. See Declaration of Jessica Mohr, filed concurrently herewith, at ¶ 2. In an

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effort to avoid incurring potentially unnecessary costs associated with expert discovery, the parties

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would like to extend the expert discovery cutoff for the limited purpose of allowing the parties to

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depose their experts at a later date in the event the case does not settle. Id. at ¶ 3. Further, and

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without waiving any objections, the parties have agreed to produce documents responsive to the

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currently outstanding document subpoenas three days prior to each expert’s deposition, to the extent

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the depositions are scheduled. Id.

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Accordingly, the parties stipulate that expert discovery should be extended to October 15,

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2014, for the limited purpose stated above. Further, the parties stipulate that the last date for hearing

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on Daubert motions should be extended as well, to account for the additional expert discovery. The

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parties have suggested October 31, 2014, which is available on the Court’s calendar, as the last date

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to hear Daubert motions, but are amenable to any date which is convenient for the Court.

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The proposed new dates are as follows:

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Deadline

Current Date

New Date

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Expert Discovery Cutoff

August 27, 2014

October 15, 2014

Hearing on Daubert Motions

September 12, 2014

October 31, 2014

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STIPULATION AND [PROPOSED] ORDER TO ENLARGE
TIME FOR EXPERT DISCOVERY CUTOFF

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CASE NO. C 11-2034 JSW (DMR)

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Dated: August 25, 2014

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WEIL, GOTSHAL & MANGES LLP
By:

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/s/ Christopher J. Cox
CHRISTOPHER J. COX
Attorneys for Plaintiff
SERGIO ALVAREZ

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Dated: August 25, 2014

ATTORNEY GENERAL OF CALIFORNIA
By:

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/s/ Sara Van Loh
SARA VAN LOH

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Attorneys for Defendants SILVEIRA,
BARNEBURG, BRANDON,
ROSENBERG, CATE, PIMENTEL,
WISE, JACQUEZ, MCGUYER, AND
BRADBURY

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I, Christopher J. Cox, am the ECF User whose ID and password are being used to file the

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Stipulation and Proposed Order to Enlarge Time for Expert Discovery Cutoff and Declaration of

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Jessica Mohr in Support thereof by Parties and Counsel. In compliance with Local Rule 5-1(i)(3),

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concurrence in the filing of the Stipulated Request and Declaration has been obtained from Sara D.

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Van Loh, counsel for Defendants, and I shall maintain records to support this concurrence for

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subsequent production for the Court if so ordered or for inspection upon request by a party.

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PURSUANT TO STIPULATION, IT IS SO ORDERED. that the deadline for expert discovery
is CONTINUED to October 15, 2014. Any motions to exclude expert witnesses shall be brought by
motions in limine in accordance with the Court's Standing Order for pretrial conferences.
Dated: September 5, 2014
______________________
HON. JEFFREY S. WHITE

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STIPULATION AND [PROPOSED] ORDER TO ENLARGE
TIME FOR EXPERT DISCOVERY CUTOFF

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CASE NO. C 11-2034 JSW (DMR)