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Sean Gunn v. Starbucks Corporation

January 3, 2011

SEAN GUNN,
PLAINTIFF,
v.
STARBUCKS CORPORATION;
DEFENDANTS.



The opinion of the court was delivered by: Honorable Jeffrey White United States District Court Judge

STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY AND EXPERT AND REBUTTAL EXPERTS

DISCLOSURE DEADLINE

WHEREAS, the Court set November 29, 2010 as the deadline for expert disclosures under Federal Rule of Civil Procedure 26(a)(2) and December 10, 2010 as the deadline for 28 rebuttal expert disclosures; 30

WHEREAS, the Court set January 18, 2011 as the deadline for discovery cut off;

WHEREAS, the parties have been diligently engaging in discovery and are currently in the process of mediation/settlement discussions;

WHEREAS, the parties stipulated to extend the deadline for expert disclosures pursuant to Federal Rules of Civil Procedure to December 30, 2010;

WHEREAS, the parties stipulated to extend the deadline for discovery to February 28, 2011;

WHEREAS, Defendant Starbucks Corporation served Plaintiff its expert disclosures on December 20, 2010;

WHEREAS, the parties believe that it would be beneficial to extend the rebuttal expert 10 disclosure and discovery cutoff deadlines while they continue to engage in mediation/settlement 11 discussions;

WHEREAS, the parties believe that good cause exists for a short extension of the discovery deadline and date on which rebuttal expert disclosures are to be made;

THEREFORE, it is hereby stipulated and agreed by and between the parties, through their counsel of record, that the discovery cutoff deadline will be extended to February 28, 2011, and that rebuttal expert disclosures pursuant to Federal Rule of Civil Procedure 26(a) will be made 16 no later than January 10, 2011.

December 27, 2010 The Law Office of Richard J. Meechan By: /s/ Richard J. Meechan Richard J. Meechan Attorney for Plaintiff SEAN GUNN DATED: December 27, 2010 Perkins Coie, LLP 25 By: /s/ Farschad Farzan Farschad Farzan Attorneys for Defendant Starbucks Corporation

WITH GOOD CAUSE APPEARING, IT IS ...


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