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Associated General Contractors of America v. California Dep't of Transportation

July 7, 2010

ASSOCIATED GENERAL CONTRACTORS OF AMERICA, SAN DIEGO CHAPTER, INC., A NONPROFIT CALIFORNIA CORPORATION, PLAINTIFF,
v.
CALIFORNIA DEPARTMENT OF TRANSPORTATION, ET AL., DEFENDANTS,
COALITION FOR ECONOMIC EQUITY AND NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE, SAN DIEGO CHAPTER, DEFENDANT-INTERVENORS.



The opinion of the court was delivered by: Judge: Hon. John A. Mendez

JOINT STIPULATION AND ORDER REGARDING TIMING OF EXPERT DISCOVERY

WHEREAS, under the Court's Pre-trial Scheduling Order the parties must make expert disclosures under Fed. R. Civ. P. 26(a)(2) by July 9, 2010; and

WHEREAS, the disclosures under Fed. R. Civ. P. 26(a)(2) must be accompanied by a written report providing "a complete statement of all opinions the witness will express and the basis and reasons for them" and "the data or other information considered by the witness in forming them;" and

WHEREAS, under the Court's Pre-trial Scheduling Order "all discovery shall be completed by September 3, 2010;" and

WHEREAS, the parties must complete fact discovery before their respective experts are able to provide a written report providing a complete statement of all opinions and the basis and reasons for them;

NOW, THEREFORE, Plaintiffs Associated General Contractors of America, San Diego Chapter, Inc.; Defendants California Department of Transportation (Caltrans), Randell Iwasaki, in his official capacity as Director of Caltrans, and Olivia Fonseca, individually, and in her official capacity as Deputy Director of Caltrans; and Defendant-Intervenors Coalition for Economic Equity, and the National Association for the Advancement of Colored People, San Diego Chapter (collectively, "the Parties") hereby stipulate and respectfully request that the Court approve the following amended schedule regarding expert disclosures and discovery;

1. The deadline for fact discovery shall remain September 3, 2010. 2. The Parties shall make expert witness disclosures under Fed. R. Civ. P. 26(a)(2) by September 3, 2010.

3. Expert discovery shall be completed by October 1, 2010. 4. The Parties agree to negotiate, in good faith, a discovery schedule regarding the timing of expert witness depositions, rebuttal expert witness disclosures, and rebuttal expert witness depositions.

DATED: July 6, 2010

Ralph W. Kasarda Attorneys for Plaintiff SHARON L. BROWNE (SBN 119246) RALPH W. KASARDA (SBN 205286) Pacific Legal Foundation

DATED: July 6, 2010

Mara E. Rosales Attorneys for Defendants RONALD W. BEALS THOMAS C. FELLENZ DANIEL A NEAR KATHRYN T. PAPALIA (SBN 173472) State of California Legal Department

MARA E. ROSALES (SBN 104844) BENJAMIN SCHNAYERSON (SBN 257857) Rosales Law Partners LLP G. SCOTT EMBLIDGE RACHEL J. ...


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