The opinion of the court was delivered by: Honorable Susan Illston United States District Judge Northern District OF California
STIPULATION AND [PROPOSED] ORDER EXTENDING THE EXPERT DISCOVERY CUT-OFF DATE
Plaintiff, Sarah Kim, Individually and as Successor in Interest to Richard D. Bae, D.D.S., Deceased ("plaintiff"), and defendants, Interdent, Inc., a Delaware corporation, a/k/a Interdent Service Corporation, a Washington corporation, a/k/a Gentle Dental, a/k/a Mountain View Dental, a/k/a Blue Oak Dental Group, a/k/a Dedicated Dental, a/k/a Affordable Dental Care, and a/k/a Capital Dental (collectively, "defendants"), by and through their respective attorneys of record, hereby jointly request that this Court issue an order, as set forth below, extending the date for the close of expert discovery, as well as the date for the parties to file any motions to compel as to expert discovery.
1. Expert discovery is currently set to close on Monday, June 28, 2010.
2. The parties have scheduled the depositions of the eleven (11) total experts, but, due to scheduling conflicts among counsel and the expert witnesses, the parties will not be able to complete all of the depositions before June 28, 2010.
3. Two expert depositions have already occurred. The remaining expert depositions
a. Steven B. Kupferman, D.M.D., M.D. and Neal L. Benowitz, M.D. on June on June 29, 2010.
b. Shiraz Buhari, M.D. on June 30, 2010.
c. Dr. John M. Greene, M.D. and Michael E. Cadra, M.D., D.M.D. on July 1, 2010.
d. Alfred Joseph Hurt, Jr., Pharm.D. and Dr. H. William Gottschalk, D.D.S. on July 2, 2010.
e. Mr. Mark Cohen on July 7, 2010.
f. Barry Gustin, M.D., M.P.H. on July 15, 2010 (tentative).
4. As a result of the above-listed schedule, the parties agree that the close of expert
5. The parties further agree that the deadline for the parties to file any motions to ...