Alonso v. Walgreen Co. et al

Filing 22

STIPULATION AND ORDER re 21 Stipulation Continuing Expert Designation Date; [Proposed] Order filed by Rosario Alonso. Designation of rebuttal experts due 11/4/2013. Expert discovery cutoff is 11/22/13. Signed by Judge Howard R. Lloyd on 10/8/13. (hrllc1, COURT STAFF) (Filed on 10/8/2013)

*E-Filed: October 8, 2013*
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Lawrence A. Organ, State Bar No. 175503
Barbara E. Figari, State Bar No. 251942
Robert J.A. Fordiani, State Bar No. 256041
EQUALITY LA WYERS, LLP
9100 Wilshire Boulevard, Suite 333E
Beverly Hills, CA 90210
(31 0) 910-9442
[phone] FAX
Attorneys for Plaintiff
ROSARIO ALONSO
Rex Darrell Berry
BERRY & BLOCK, LLP
2150 River Plaza Drive, Suite 415
Sacramento, CA 95833
[phone]
[phone] FAX
Attorneys for Defendant
WALGREEN CO.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ROSARIO ALONSO, an individual,

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Plaintiff,

v.
WALGREEN CO., and DOES 1 -50,
inclusive,
Defendants.

) Case No. 5:12-CV-06269-Hlli,
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)
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) STIPULATION CONTINUING EXPERT
)) DESIGNATION DATE; [PROPOSED]
) ORDER
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)

)

PlaintiffRosario Alonzo ("Plaintiff') and Defendants Walgreen Co. ("Defendant"),
through their respective counsel of record, stipulate and agree as follows:
The parties have engaged in significant written and deposition discovery. However, in
light of availability and location, the parties have agreed on deposition dates for indispensable
witnesses to occur after the discovery cut-off date. The indispensable witnesses to be deposed
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STIPULATION

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are Walgreen's person most knowledgeable and human resource person, which are currently set

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to take place in Chicago, Illinois on September 25, 2013 and September 26, 2013, respectively.
WHEREAS the testimony sought at deposition of Walgreen's person most

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knowledgeable and human resource person is important for the purpose of any retained expert's
opinion as to the facts and circumstances involved in this matter, and is therefore significant for
any expert's reports or findings that may either be relied upon by the parties or assist the finder
of fact.
WHEREAS, the original date for designation of expert witnesses with reports was
August 6, 2013.
WHEREAS, the parties jointly stipulated on June 4, 2013 to extend the discovery-cut-off
date and designation of experts with reports from August 6, 2013 to September 23, 2013;

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rebuttal experts with reports deadline extended from September 3, 2013 to October 21, 2013;

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expert discovery cut-off date extended from September 17, 2013 to November 4, 2013; Last Day

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for Hearings on Dispositive Motions extended from November 12, 2013 at 10:00 a.m. to

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December 31, 2013 at 10:00 a.m.; and Final Pretrial Conference extended from December 10,

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2013 at 1:30 p.m. to February 11, 2014.

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WHEREAS, the signed joint stipulation was entered by the Court on June 5, 2013.

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WHEREAS, per the Court's Local Rules, counsel for the parties have met and conferred

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on scheduling dates and location of remaining depositions and extending the date for each side

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to designate experts with reports.

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WHEREAS, the parties jointly agreed to extend the date for designation of expert
witnesses with reports to October 4, 2013;
NOW THEREFORE, The undersigned parties submit this stipulated request and
respectfully request that the Court issue an Order as follows:
In order to accommodate the parties in completing the deposition discovery of
indispensable witnesses, and providing such information for possible expert witnesses and their
preparation of reports, the parties respectfully request an extension ofthe deadline to designate
experts with reports, and the Court include in its Order the following:
The designation of experts with reports will be extended from September 23, 2013 to

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STIPULATION

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October 4, 2013 or any such later dates as the Court see fit;
The designation of rebuttal experts with reports deadline will be extended from October
21, 2013 to November 4, 2013, or any such later dates.
The expert discovery cut-off date will be extended from November 4, 2013 to November
22, 2013, or any such later dates.

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IT IS SO STIPULATED:

EQUALITY LA WYERS

Date: September 25, 2013

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Is/ Robert J.A. Fordiani
LARRY ORGAN
BARBARA FIGARI
ROBERT FORDIANI

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Attorney for Plaintiff

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Date:

September~2013

BERRY & BLOCK, LLP

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~~

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RE~LBERRY ~

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Attorney for Defendant

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IT IS SO ORDERED

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Date: _ _ _ _ _, 2013
October 8

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HOWARD R LL YOD R. LLOYD

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UNITED STATES MAGISTRATE
JUDGE

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STIPULATION