Hernandez v. Baker Concrete Construction, Inc.

Filing 24

ORDER by Judge Haywood S. Gilliam, Jr. Granting 23 Stipulated Scheduling Order.Motions due by 10/29/2018; Close of Fact Discovery due by 1/25/2019; Designation of Experts due by 4/23/2019; Motion Hearing set for 4/23/201902:00 PM in Oakland, Courtroom 2, 4th Floor before Judge Haywood S. Gilliam Jr.; Designation of Rebuttal Experts due by 5/21/2019; Close of Expert Discovery due by 6/18/2019; Final Pretrial Conference set for 8/13/2019 03:00 PM in Oakland, Courtroom 2, 4th Floor; Jury Selection /Jury Trial set for 8/26/2019 08:30 AM in Oakland, Courtroom 2, 4th Floor before Judge Haywood S. Gilliam Jr. (ndrS, COURT STAFF) (Filed on 9/12/2018)

1 BRYAN J. MCCORMACK (SBN 192418)

[e-mail]

2 MCCORMACK & ERLICH, LLP

150 Post Street, Suite 742

3 San Francisco, CA 94108

Telephone: [phone]

4 Facsimile: [phone]
5 Attorneys for Plaintiff
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JAMES HERNANDEZ
ROGER M. MANSUKHANI (SBN: 164463)

7 [e-mail]

CRAIG D. NICKERSON (SBN: 215067)

8 [e-mail]

MARSHALL R. LURTZ (SBN: 296254)

9 [e-mail]

GORDON REES SCULLY MANSUKHANI, LLP

10 633 West Fifth Street, 52nd Floor

Los Angeles, CA 90071

11 Telephone: [phone]
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Facsimile: [phone]
Attorneys for Defendant

13 BAKER CONCRETE CONSTRUCTION, INC.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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17 JAMES HERNANDEZ

Assigned to Hon. Judge Haywood S.
Gilliam, Jr.

Plaintiff,

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CASE NO.: 4:18-cv-03226-HSG

v.

20 BAKER CONCRETE

CONSTRUCTION, INC., a Ohio

21 Corporation,
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Defendants.

STIPULATED SCHEDULING
ORDER
Complaint Filed: May 30, 2018

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STIPULATED SCHEDULING ORDER
Case No. 4:18-cv-03226-HSG

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The parties, James Hernandez (“Plaintiff”) and Baker Concrete Construction,

2 Inc. (“Defendant” or “Baker”), through undersigned counsel of record, hereby
3 propose the following Stipulated Scheduling Order:
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PROPOSED SCHEDULE OF PRETRIAL AND TRIAL DATES

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Matter

Deadline

Parties’ Request

Last Day to Comply
with General Order 71

Scheduling Conference
Date Plus 38 days

October 5, 2018

Last Day to File
Motions to Add Parties
and Amend Pleadings

Scheduling Conference
Date plus 60 Days

October 29, 2018

Last Day to Conduct
Settlement Proceedings

Scheduling Conference
Date plus 120 Days

December 26, 2018

Fact Discovery Cut-Off

18 weeks before the
Final Pretrial
Conference (“FPTC”)

January 25, 2019

Last Day to Serve
Initial Expert Reports

16 weeks before the
FPTC

April 23, 2019

Disposition Hearing
Deadline (except
Daubert and all
other Motions in
Limine)

16 weeks before the
FPTC

April 23, 2019

Last Day to Serve
Rebuttal Expert
Reports

12 weeks before the
FPTC

May 21, 2019

Expert Discovery CutOff

8 weeks before the
FPTC

June 18, 2019

Last Day to File
Daubert Motions

7 weeks before the
FPTC

June 25, 2019

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STIPULATED SCHEDULING ORDER
Case No. 4:18-cv-03226-HSG

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Matter

Deadline

Parties’ Request

Last Day to File
Motions in Limine
(other than Daubert
Motions)

4 weeks before the
FPTC

July 16, 2019

Final Pre-Trial
Conference

FPTC

August 13, 2019

Trial

Trial

August 26, 2019

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Dated: September 11, 2018

GORDON REES SCULLY MANSUKHANI

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By: /s/ Marshall R. Lurtz
Roger M. Mansukhani
Craig D. Nickerson
Marshall R. Lurtz
Attorneys for Defendant
Baker Concrete Construction, Inc.

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Dated: September 11, 2018

McCormack and Erlich, LLP

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By: /s/ Bryan J. McCormack
Bryan J. McCormack
Attorneys for Plaintiff
James Hernandez

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STIPULATED SCHEDULING ORDER
Case No. 4:18-cv-03226-HSG

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SCHEDULING ORDER
Based on the Joint Stipulation of the parties, and good cause appearing
therefore, the above STIPULATED SCHEDULING ORDER is approved as the
Scheduling Order for this case and all parties shall comply with its provisions.
IT IS SO ORDERED except the Disposition Hearing Deadline (except

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Daubert and all other Motions in Limine) will be heard on April 25, 2019 at 2:00 p.m.
Dated: September 12, 2018

_____________________________
Hon. Judge Haywood S. Gilliam, Jr

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1147508/36910109v.1

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STIPULATED SCHEDULING ORDER
Case No. 4:18-cv-03226-HSG