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Rodriguez v. D.M. Camp & Sons

November 15, 2010

FERNANDO RODRIGUEZ AND GUADALUPE HERRERA, ON BEHALF OF THEMSELVES AND ALL OTHER SIMILARLY SITUATED INDIVIDUALS, PLAINTIFFS,
v.
D.M. CAMP & SONS AND DOES 1-20, DEFENDANTS.



The opinion of the court was delivered by: Sandra M. Snyder

CLASS ACTION STIPULATION AND ORDER EXTENDING CASE DEADLINES

The parties in this case are engaged in discussions regarding mediation and have mutually agreed to a mediator. Based upon the mediator's schedule, the parties expect to participate in a mediation session in January 2011. However, certain key deadlines, including class certification discovery (12/30/10), expert disclosures (1/7/11) and expert discovery (2/18/11), are set to come up before the parties' mediation or soon thereafter.

Although the parties have engaged in formal discovery, they have not completed all class certification and expert discovery at this time. In light of the parties' plan to mediate the case and in an effort to avoid unnecessary costs, the parties request that all deadlines set forth in the scheduling order of March 24, 2010 be extended according to the proposed dates to allow the parties to mediate the case without the need of completing class certification and expert discovery by the current deadlines. The parties' proposed modification of the deadlines takes into account the staggered deadlines, including trial dates, in the related cases, which plaintiffs' counsel is currently litigating.

Therefore, the parties request modification of the deadlines as follows:

Current Extension

Class Discovery Deadline: 12/30/10 at least 11/11/11

Merit Discovery Deadline: 4/8/11 at least 4/6/12

Expert Disclosure Deadline: 1/7/11 at least 10/7/2011

Expert Discovery Deadline: 2/18/11 at least 11/01/2011

Class Certification Filing Deadline: 3/1/11 at least 11/16/2011

Non-Dispositive Motion Filing Deadline: 4/1/11 at least 4/16/2012

Dispositive Motion Filing Deadline: 4/29/11 at least 1/13/2012

Settlement Conference Date: N/A ...


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