Aghmane v. Bank of America Corporation N.A.

Filing 88

ORDER by Magistrate Judge Donna M. Ryu granting 85 Stipulation to continue dates for Expert Discovery. Signed by Magistrate Judge Donna M. Ryu on 10/20/14. (ig, COURT STAFF) (Filed on 10/20/2014)

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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Roxanne M. Wilson (SBN 94627)
Email:
[e-mail]
REED SMITH LLP
355 South Grand Avenue, Suite 2900
Los Angeles, CA 90071-1514
Telephone: [phone]
Facsimile: [phone]
Renee C. Feldman (SBN 253877)
Email:
[e-mail]
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile: [phone]
Don A. Innamorato (NJ SBN 036941986)
(appearance pro hac vice)
Email:
[e-mail]
Meghan O. Offer (NJ SBN 033762005)
(appearance pro hac vice)
Email:
[e-mail]
REED SMITH LLP
Princeton Forrestal Village
136 Main Street, Suite 250
Princeton, NJ 08540-7839
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
Bank of America, N.A.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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No.: 13-03698 DMR

SALMA AGHMANE,
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STIPULATION AND ORDER TO
CONTINUE DATES FOR EXPERT
DISCOVERY

Plaintiff,
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vs.
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BANK OF AMERICA CORPORATION; BANK
23 OF AMERICA, N.A.; MERRILL LYNCH &
CO., INC., and DOES One through 200,
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Defendants.
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STIPULATION AND ORDER TO CONTINUE DATES FOR EXPERT DISCOVERY

US_ACTIVE-119590348

STIPULATION

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Plaintiff Salma Aghmane (“Plaintiff”) and Defendant Bank of America, N.A. (“Defendant”),

3 by and through their counsel of record, hereby stipulate and agree as follows:
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1.

Plaintiff commenced the above-referenced action on June 27, 2013 in the Superior

5 Court of California, County of San Francisco. Defendant removed the matter to the United States
6 District Court, Northern District of California on August 9, 2013. Trial is set for January 12, 2015.
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2.

Plaintiff has represented to Defendant that her only designated expert (an economist)

8 is unavailable for deposition on the date noticed by Defendant, or any date before the current
9 deadline for Defendant’s rebuttal disclosure and rebuttal report (October 21, 2014). Based on the

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 dates of availability of Plaintiff’s designated expert for deposition, and Defendant’s desire to depose
11 Plaintiff’s designated expert prior to its deadline for rebuttal expert disclosure and rebuttal expert
12 reports, the parties agreed to extend the expert discovery deadlines.
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3.

Accordingly, based on the foregoing, the parties hereby stipulate to, and respectfully

14 request that the Court grant, a continuance of the dates for expert discovery as follows:
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Rebuttal Expert Disclosure and Rebuttal Reports Provided by: November 12, 2014

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All Discovery from Experts Shall be Completed by: November 25, 2014

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4.

This stipulation and requested continuance will not result in prejudice to any party

18 and is not expected to have any impact on judicial proceedings.
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5.

Nothing in this stipulation shall constitute a waiver of any arguments or defenses that

20 Plaintiff or Defendant may wish to assert in the action, all of which are expressly reserved.
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IT IS SO STIPULATED.

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24 DATED: October 17, 2014
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REED SMITH LLP
By:

_/s/ Renee Feldman___________
Roxanne M. Wilson
Renee C. Feldman
Attorneys for Defendant
Bank of America, N.A.

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STIPULATION AND ORDER TO CONTINUE DATES FOR EXPERT DISCOVERY

1 DATED: October 17, 2014
AIMAN-SMITH & MARCH

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By:

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/s/ Hallie Von Rock_____________
Randall B. Aiman-Smith
Reed W.L. March
Hallie Von Rock
Attorneys for Plaintiff
Salma Aghmane

Pursuant to Local Rule 5.1(i)(3) the undersigned attests that concurrence in the filing of the

7 document has been obtained from each of the signatories.
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9 DATED: October 17, 2014
REED SMITH LLP
By:

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_/s/ Renee Feldman ____________
Roxanne M. Wilson
Renee C. Feldman
Attorneys for Defendants
Bank of America Corporation; Bank of America,
N.A.; Merrill Lynch & Co., Inc.

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ORDER

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The Court, having duly considered the parties’ stipulation as set forth above, and good cause
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appearing, hereby orders:
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The expert discovery dates shall be continued as follows:
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Rebuttal Expert Disclosure and Rebuttal Reports Provided By: November 12, 2014
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All Discovery from Experts Shall be Completed By: November 25, 2014

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M. Ryu

onna
________________________
Judge D
Donna M. Ryu
United States Magistrate Judge
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DATED: 10/20/2014

NO

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D

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IS SO O
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FO

IT IS SO ORDERED .
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S DISTRICT
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UNIT
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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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F
D IS T IC T O
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STIPULATION AND ORDER TO CONTINUE DATES FOR EXPERT DISCOVERY