Todd v. AT&T Corp. et al

Filing 76

ORDER by Judge Haywood S. Gilliam, Jr. Granting 75 Stipulation EXTEND DISCOVERY DEADLINE AND DEADLINE TO DISCLOSE REBUTTAL EXPERTS. (ndrS, COURT STAFF) (Filed on 3/27/2017)

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Balam O. Letona, Esq. (Cal. Bar No. 229642)
Law Office of Balam O. Letona, Inc.
1509 Seabright Avenue, Suite C1
Santa Cruz, CA 95062
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Luke Wallace
Robert David Humphreys
HUMPHREYS WALLACE HUMPHREYS, P.C.
9202 S. Toledo Avenue
Tulsa, OK 74137
[e-mail]
[e-mail]
Pro Hac Vice

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Attorney for Plaintiff:
Cynthia Todd
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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CYNTHIA TODD,

Case No. 16-cv-03357-HSG

Plaintiff,
vs.

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AT&T CORP., EQUIFAX INFORMATION
SERVICES LLC., NATIONAL CONSUMER
TELECOM and UTILITIES EXCHANGE, INC.,
EXPERIAN INFORMATION SOLUTIONS INC.,
and DOES 1-10.

STIPULATION AND ORDER
EXTENDING TIME FOR
DISCOVERY AND EXTENDING
DEADLINE TO DESIGNATE
REBUTTAL EXPERTS

Defendants.

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The parties hereby request and stipulate to move the non-expert and expert discovery

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deadline to April 28, 2017 and the deadline to designate rebuttal experts with reports to April

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STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINE AND
REBUTTAL EXPERTS

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14, 2017. Currently, the discovery deadline closes on April 14, 2017 and the deadline to

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designate rebuttal experts is March 31, 2017. All other dates to remain the same.

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The parties have engaged in extensive written discovery including follow-up

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discovery. Plaintiff’s deposition was conducted on March 6, 2017. The remaining defendant

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depositions have been noticed and will be conducted in April 2017. On March 17, 2017,

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Plaintiff disclosed her expert with report. The parties have scheduled mediation to occur on

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April 20, 2017, with the Honorable Judge Ware, Ret. The parties have not yet scheduled the

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deposition of Plaintiff’s expert. Furthermore, Plaintiff expects to depose Defendant’s rebuttal

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expert.

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The parties believe additional time is needed to conduct meaningful discovery, have a

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productive mediation session, depose Plaintiff’s and Defendants’ rebuttal experts and that

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moving the discovery deadline to April 28th and the deadline to designate rebuttal experts to

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April 14th will facilitate this goal.

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Previously, the parties agreed to move the deadline to disclose experts to March 17,

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2017 and to move the close of non-expert discovery to April 14, 2017. See Docket #68, #70.

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All other dates to remain the same.

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As such, the parties agree and stipulate to the following:

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April 14, 2017

Last Day to Designate Rebuttal Experts with Reports

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April 28, 2017

Fact and Expert Discovery Closes

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SO STIPULATED:

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Dated: March 22, 2017

AT&T SERVICES, INC. - LEGAL
DEPARTMENT

By: /s/ Robert B. Mullen
Robert B. Mullen

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STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINE AND
REBUTTAL EXPERTS

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Atto
orneys for D
Defendant
AT& CORP.
&T

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Dated March 22 2017
d:
2,

NG
KING & SPALDIN LLP

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By: /s/ J. A
Anthony Lov
ve
J. Antho Love
ony
Attorne for Defen
ey
ndant Equifa Informati
ax
ion
Solution Inc., and NCTUE
ns,
d

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Dated March 22 2017
d:
2,

LAW OFF
FICE OF BA
ALAM O. L
LETONA, IN
NC.

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By: /s/ Ba
alam O. Let
tona
Bala O. Leton
am
na
Attor
rney for Pla
aintiff
CYN
NTHIA TOD
DD

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PUR
RSUANT TO STIPULA
O
ATION, IT IS SO OR
T
RDERED.

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TED: March 27, 2017
DAT

______
___________
__________
_______
Hon Haywood S. Gilliam Jr.
n.
d
m,
Uni
ited States D
District Jud
dge

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STIPULAT
TION AND ORDER EX
XTENDING DISCOVE
G
ERY DEAD
DLINE AND
D
REBUTTAL EXP
PERTS

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