Ang et al v. Bimbo Bakeries USA, Inc.

Filing 200

ORDER by Judge Haywood S. Gilliam, Jr. Granting 196 Stipulation EXTENDING EXPERT WITNESS DEADLINES. Opening Reports due by 6/4/2019; Rebuttal Reports due by 7/5/2019 and Close of Expert Discovery due by 8/5/2019. (ndrS, COURT STAFF) (Filed on 5/15/2019)

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Ben F. Pierce Gore (SBN 128515)
PRATT & ASSOCIATES
634 North Santa Cruz Avenue
Suite 204
Los Gatos, CA 95030
Telephone: [phone]
[e-mail]
Keith M. Fleischman (admitted pro hac vice)
Joshua D. Glatter (admitted pro hac vice)
THE FLEISCHMAN LAW FIRM, PLLC
565 Fifth Avenue, Seventh Floor
New York, New York 10017
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs

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Mark C. Goodman (SBN 154692)
[e-mail]
Anne M. Kelts (SBN 298710)
[e-mail]
BAKER & McKENZIE LLP
Two Embarcadero Center, 11th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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ALEX ANG and LYNNE STREIT,
individually and on behalf of all others
similarly situated,
Plaintiffs,
v.

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BIMBO BAKERIES USA, INC.,

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Defendant.

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STIPULATION AND ORDER
Case No. CV13-01196-HSG

Case No. 4:13-CV-1196-HSG
STIPULATION EXTENDING EXPERT
WITNESS DEADLINES; ORDER
Judge: Hon. Haywood S. Gilliam, Jr.
Action Filed: March 18, 2013

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Pursuant to Northern District Rule 6-2, and subject to the Court’s approval, Plaintiffs Alex
Ang and Lynne Streit (collectively, “Plaintiffs”) and defendant Bimbo Bakeries U.S.A., Inc.
(“Defendant”) (collectively “the Parties”) respectfully submit the following Stipulation and
proposed Order.
WHEREAS, the Parties are actively engaged in productive settlement negotiations;
WHEREAS, the Court has ordered the Parties to schedule a teleconference with the ADR
Unit and to advise the Court no later than May 17, 2019 as to the scheduled date;

WHEREAS, the deadline to exchange opening expert reports is May 14, 2019;
WHEREAS, counsel for the Parties believe that a three week extension of the expert
witness deadlines will aid settlement negotiations and enable the parties to avoid significant
expense;
WHEREAS, there have been no previous extensions of the pretrial schedule in this action;
WHEREAS, a three week extension of the expert witness deadlines will have no effect on
the remainder of the schedule in this action;
The Parties stipulate to the following three week extension of each expert witness deadline,
and respectfully request that the Court enter the accompanying proposed Order:
Deadline to exchange opening expert reports

June 4, 2019

Deadline to exchange rebuttal expert reports

July 5, 2019

Expert discovery deadline

August 5, 2019

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Dated: May 14, 2019

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/s/ Pierce Gore
Ben F. Pierce Gore (SBN 128515)
PRATT & ASSOCIATES
1871 The Alameda, Suite 425
San Jose, CA 95126
Telephone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Plaintiffs

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STIPULATION AND ORDER
Case No. CV13-01196-HSG

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/s/ Mark C. Goodman
Mark C. Goodman (Bar No. 154692)
BAKER & MCKENZIE LLP
Two Embarcadero Center, Suite 1100
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Defendant

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STIPULATION AND ORDER
Case No. CV13-01196-HSG
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ECF ATTESTATION

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I, Pierce Gore, am the ECF User whose ID and password are being used to file the

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following: STIPULATION AND [PROPOSED] ORDER. In compliance with General Order

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45, X.B., I hereby attest that Mark C. Goodman has concurred in this filing.

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May 14, 2019

Pierce Gore

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ORDER
Pursuant to Stipulation of the parties, and good cause appearing therefor, the Court hereby
approves the Stipulation, and enters it as the Order of the Court.

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Dated: May 15, 2019
Hon. Haywood S. Gilliam, Jr.
United States District Judge

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STIPULATION AND ORDER
Case No. CV13-01196-HSG

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