Dang v. Sutter's Place, Inc. et al

Filing 87

STIPULATION AND ORDER 77 to Continue Trial Deadlines Re: Expert Discovery. Signed by Judge Ronald M. Whyte on 3/2/12. (jg, COURT STAFF) (Filed on 3/2/2012)

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ANN A. NGUYEN (SBN 178712)
ROBINSON & WOOD, INC.
227 N. First Street
San Jose, California 95113
Telephone: [phone]
Facsimile:
408-298-0477
Email:
[e-mail]

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Attorneys for Plaintiff DANG

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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CUC DANG,
Plaintiff,

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vs.

STIPULATION AND
[]
ORDER TO CONTINUE TRIAL
DEADLINES RE EXPERT DISCOVERY

SUTTER’S PLACE, INC. dba BAY 101 or
BAY 101 CASINO, et. al.,

[Fed. R. Civ. P. 35]

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Case No. 10-CV-02181 (RMW) (PSG)

Defendants.
Complaint Filed: May 20, 2010

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On December 12, 2011, the Court issued an Order based upon a December 9, 2011

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Stipulation submitted by Plaintiff and Defendant for an independent mental examination of

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Plaintiff to take place on January 24, 2012. Plaintiff has just received notice that her appearance

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at a Naturalization Oath Ceremony is required on January 24, 2012 to complete her

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naturalization process to become a US citizen. To permit Plaintiff to attend the Naturalization

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Oath Ceremony, the parties have agreed to continue Plaintiff's IME for three (3) days. In order

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to avoid prejudice to Defendant for this brief continuance, the parties have also agreed to

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continue the trial deadlines pertaining to expert discovery.

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Accordingly, Plaintiff, Cuc Dang (“Dang”), and defendant, Sutter’s Place, Inc. dba Bay
101 (“Bay 101”) (collectively “the parties”), by and through their respective attorneys of record,

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717412

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STIPULATION AND [] ORDER TO CONTINUE TRIAL DEADLINES RE EXPERT DISCOVERY;
CASE NO. 10-CV-02181 (RMW) (PSG)

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hereby submit this stipulation and request that the Court allow them a brief continuance of the

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trial deadlines pertaining to expert discovery, as follows:

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EVENT

FORMER
DEADLINE
Fri. Mar. 16, 2012

NEW DEADLINE

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Last day to disclose experts

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Last day to identify rebuttal/opposition Fri. Apr. 13, 2012
experts and serve rebuttal/opposition
reports

Fri. Apr. 20, 2012

Close of expert discovery

Tue. May 1, 2012

Tue. May 8, 2012

Last day to file motions on expert
discovery

Mon. May 21, 2012

Fri. May 25, 2012

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Fri. Mar. 23, 2012

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IT IS SO STIPULATED.

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[In accordance with General Order 45.X.B., Ann Nguyen, counsel for Plaintiff, attests that

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Defendant's counsel, Matthew Schechter, has concurred in this filing.]

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Dated: January 11, 2012

McMANIS FAULKNER

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/s/
MATTHEW SCHECHTER
Attorneys for Defendant
SUTTER’S PLACE, INC. dba BAY 101

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Dated: January 11, 2012

ROBINSON & WOOD, INC.

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/s/
ANN A. NGUYEN
Attorneys for Plaintiff,
CUC DANG

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717412

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STIPULATION AND [] ORDER TO CONTINUE TRIAL DEADLINES RE EXPERT DISCOVERY;
CASE NO. 10-CV-02181 (RMW) (PSG)

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ORDER
Good cause appearing therefor, the expert discovery trial deadlines shall be continued as
set forth in the above stipulation.

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Dated: ________________________

_________________________________
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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717412

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STIPULATION AND [] ORDER TO CONTINUE TRIAL DEADLINES RE EXPERT DISCOVERY;
CASE NO. 10-CV-02181 (RMW) (PSG)