Richardson v. Fluor Corporation

Filing 66

ORDER by Judge Saundra Brown Armstrong Granting 65 Stipulation. (ndr, COURT STAFF) (Filed on 6/12/2014)

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Benjamin Elliot Kaplan, SBN 43456
[e-mail]
Douglas Cameron MacLellan, SBN 169933
[e-mail]
Law Offices of KAPLAN & MACLELLAN
601 Van Ness Avenue, Suite 2090
San Francisco, California 94102
Telephone: [phone]
Facsimile: [phone]

6 Attorneys for Plaintiff
TIMOTHY RAY RICHARDSON
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8 Thomas M. McInerney CA Bar No. 162055
[e-mail]
9 Jill V. Cartwright CA Bar No. 260519
[e-mail]
10 Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
Steuart Tower, Suite 1300
11 One Market Plaza
San Francisco, CA 94105
12 Telephone:
415.442.4810
Facsimile:
415.442.4870
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Attorneys for Defendants
14 FLUOR CORPORATION and
FLUOR MAINTENANCE SERVICES, INC.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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19 TIMOTHY RAY RICHARDSON
Plaintiff,

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v.

Case No. CV-13-1908-SBA
STIPULATION AND ORDER FOR
EXTENDING EXPERT DISCOVERY
DEADLINES

22 FLUOR CORPORATION; FLUOR
MAINTENANCE SERVICES, INC.; DOES 1
23 THROUGH 10, INCLUSIVE,
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Defendant.

Complaint Filed: April 25, 2013
Trial Date:
October 15, 2014

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Case No. CV-13-1908-SBA
STIPULATION AND [PROPOSED] ORDER FOR EXTENDING EXPERT DISCOVERY DEADLINES

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Plaintiff Timothy Ray Richardson and defendants Fluor Corporation (“Fluor”) and Fluor

2 Maintenance Services, Inc. (“FMS”), through their respective counsel, respectfully request the
3 Court modify its pretrial scheduling order (Dkt No. 38) to extend the deadline to exchange rebuttal
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expert reports and the deadline for expert discovery.
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The Parties request the Court extend the deadline to exchange expert rebuttal

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disclosures to June 20, 2014. The current deadline is June 13, 2014 and the parties request a one

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week extension. The extension is requested, in part, because defendants’ expert, Dr. Ronald

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Roberts was delayed in sending his raw data to plaintiff’s expert.

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2.

The Parties request the Court extend the deadline for expert discovery to July 18,

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2014. The current deadline to complete expert discovery is July 11, 2014. This one week

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extension will provide greater flexibility in scheduling the anticipated expert depositions.

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3.

Neither of the requested extension will conflict with any other pretrial scheduling

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4.

Therefore, pursuant to Local Rule 16-2(d)-(e) and Local Rule 7, the Parties herby

15 submit this stipulation for modification of the pretrial scheduling order (Dkt No. 38).
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17 DATED: June 12, 2014

LAW OFFICES OF KAPLAN & MACLELLAN

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By:
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Attorneys for Plaintiff
TIMOTHY RAY RICHARDSON

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22 DATED: June 12, 2014
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/s/ Douglas MacLellan
Douglas Cameron MacLellan

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
By:

/s/ Jill Cartwright
Thomas M. McInerney
Jill V. Cartwright

Attorneys for Defendants
FLUOR CORPORATION and
FLUOR MAINTENANCE SERVICES, INC.

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Case No. CV-13-1908-SBA
STIPULATION AND [PROPOSED] ORDER FOR EXTENDING EXPERT DISCOVERY DEADLINES

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SIGNATURE ATTESTATION
Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this

3 document has been obtained from the other signatories.
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5 DATED: June 12, 2014

By: /s/ Jill V. Cartwright
Jill V. Cartwright

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: ______________________
6/12/2014
Saundra Brown Armstrong
United States District Judge
18141917.1

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Case No. CV-13-1908-SBA
STIPULATION AND [PROPOSED] ORDER FOR EXTENDING EXPERT DISCOVERY DEADLINES