Pacific Gas & Electric Company v. Simon Property Group, Inc. et al

Filing 23

STIPULATION AND ORDER extending deadline to complete ENE to 10/18/13. Signed by Magistrate Judge Howard R. Lloyd on August 21, 2013. (hrllc1, COURT STAFF) (Filed on 8/21/2013)

*E-FILED: August 21, 2013*
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LAW OFFICES OF DAWN CEIZLER
DAWN CEIZLER, BarNo. 214873
1990 N. California Blvd., Suite 305
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff
Pacific Gas and Electric Company

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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PACIFIC GAS AND ELECTRIC
COMPANY, a California Company
Plaintiff.
vs.
SIMON PROPERTY GROUP, INC. and
DOES 1-10, inclusive,
Defendants.

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Case No. CV13-1043-HRL

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STIPULATION TO EXTEND
DEADLINE FOR COMPLETION OF
ALTERNATIVE DISPUTE
RESOLUTION; PROPOSED ORDER

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Current Deadline: September 18,2013
Proposed New Date: October 18,2013

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Pursuant to Civil L.R. 5-5, the parties represent as follows:

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The parties attempted to timely exchange their initial disclosures pursuant to the

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joint case management statement filed in this matter. Both finns have had issues with their mail

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and due to an unknown reason, Defendant's initial disclosure production was not received until

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August 17, 2013. Both parties agree that in order to properly present their case to the Early

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Neutral Evaluator, they will need to conduct some preliminary discovery, including depositions.

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Plaintiff is unprepared to make determinations as to which depositions and/or discovery to

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conduct until it has had the opportunity to review the initial disclosures. Given that the Early

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Neutral Evaluator has requested statements be provided ten (1 0) days before the hearing, such

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would require the parties to complete the initial disclosures and preliminary discovery by

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September 8, 2013. Neither party believes this is possible in light of their current obligations and

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both feel such initial discovery is necessary to make the Early Neutral Evaluation as meaningful

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as possible.
- 1STIPULATION TO EXTEND ADR DEADLINE CV:13-1043

The parties conducted their initial telephonic session with the Early Neutral

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Evaluator on August 16, 2013 and they agreed that a short continuance through October 18, 2013

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would be appropriate and the Early Neutral Evaluator, Samuel Barnum, also agreed that such was

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reasonable.
IT IS HEREBY STIPULATED that the current deadline of September 18, 2013

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for completion of alternative dispute resolution should be continued until October 18, 2013.

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Dated:

August~ 2013

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~S.

amuel S. Baxter, Esq.
Counsel for Defendant Simon Property Group, Inc.
Dated: August ~ 2013
Dawn Ceizler,q:
Counsel for Plaintiff Pacific Gas and Electric
Company

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The stipulation of the parties having been considered by the Court, and good cause
appearing,
IT IS SO ORDERED

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Dated: August_, 2013
Howard R. Lloyd
United States Magistrate Judge

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STIPULATION TO EXTEND ADR DEADLINE CV: 13-1043