Alonso v. Walgreen Co. et al

Filing 27

STIPULATION AND ORDER re 24 STIPULATION WITH PROPOSED ORDER RE EXPERT DISCOVERY filed by Walgreen Co. Signed by Magistrate Judge Howard R. Lloyd on 10/28/2013. (hrllc1, COURT STAFF) (Filed on 10/28/2013)

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REX DARRELL BERRY, State Bar No. 110219
BERRY & BLOCK LLP

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2150 River Plaza Drive, Suite 415
Sacramento, CA 95833
(916) 564~2000
[phone] FAX

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*E-Filed: October 28, 2013*

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Attorneys for Defendant

WALGREEN CO.

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UNITED STATES DISTIUCT COURT

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NORTHl\RN DISTRICT OF CALIFORNIA

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ROSARIO ALONSO, an individual,

) Case No. 5: 12-CV-06269-HRL
)

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Plaintiff,

v.

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) STIPULA'I'ION AND [PROPOSEDJ ORDER
) REGARDING EXPERT DISCOVERY

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

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Defendants.

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I. STIPULATION

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The parties hereto, through their undersigned counsel of record, hereby stipulate as follows:

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1.

The current cut-off date for expert discovery is November 22, 2013;

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2.

Walgreen Co. ("Walgreens") is in the process of preparing, <mel will be filing, a

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motion for summary judgment and/or summary adjudication;

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In order to proceed efficiently and cost-effectively with litigation, the parties agre~:

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that the depositions of Plaintiff's retained and non-retained experts, Ann Marie

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Noel and Dr. Shabi Kahn, may take place, if necessary, after the Court rules on

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Walgreen's motion for summary judgment and/or summary adjudication.

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III

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I I/

s·riPULATION AND [PROPOSED] ORDER REGARDING EXPERT DISCOVERY

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The parties agree that under any circumstances, the depositions of Plaintiffs

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experts, ifne<.;essary, will take p[a<.;c prior to January 31,2014, well in advance of

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the Pretrial Conference in this case currently set for March 11, 2014.

February
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DATED: October 18,:2013

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DATED: October 18, 2013

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H. ORDER [PROPOSED]
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Based on the foregoing stipulation ofthe parties, and for good cause shown, IT IS
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HEREBY ORDERED:

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The depositions of Plaintiff's retained and non-retained experts, Ms. Ann Marie Noel and
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Dr. Shabi Kahn, may take place, if necessary, following the close of expert discovery on

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November 22,2013, but will be completed on or before January 15,2014.

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DAT'ED: October 18, 2013

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Bv
• ffclward R.

uo-v-a--··--·--···--·

United States :tV1agistrate Judge

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STIPULA TlON AND [PROPOSED! ORDER REGARDING EXPERT DISCOVERY