The opinion of the court was delivered by: The Honorable Maxine M. Chesney
STIPULATION AND [PROPOSED] ORDER MODIFYING ORDER REGARDING PRETRIAL PREPARATIONS
the fact discovery cutoff for purposes of taking depositions, the expert discovery deadlines, and 4 the deadlines to file dispositive motions. In order to allow completion of the discovery, the 5 parties stipulate to and request the Court to issue an order modifying the Pretrial Preparation Order ("Scheduling Order"), filed on December 6, 2010 [Docket No. 57]. With the exception of 7 the parties' proposed modifications, described below, the parties stipulate to and request that the Non-Expert Discovery Cutoff. The Scheduling Order provides that fact discovery shall be completed by April 22, 2011. The parties stipulate to and request the Court to order an extension 11 of this date to May 20, 2011 for the purpose of conducting depositions only. The parties stipulate 12 that no further written discovery shall be propounded including requests for admissions, 13 interrogatories, and production of documents under Federal Rules of Civil Procedure 33, 34, or 36 14 and subpoenas to produce documents under Rule of Civil Procedure 45. This stipulation, 15 however, does not preclude or limit any parties' ability to request or compel further responses to 16 discovery that has already been propounded provided any motion to compel fact discovery is filed 17 on or before the existing deadline of April 29, 2011. See N.D. Cal. L.R. 37-3. follows: completed on or before June 15, 2011. The parties stipulate to and request the Court to order an 27 extension of this date to July 6, 2011.
As a part of the meet and confer process, the parties agreed to file a stipulation extending Court order no changes to the remaining dates in the Scheduling Order.
Designation of Experts. The Scheduling Order provides for the deadlines as follows:
x Plaintiff/Defendant: No later than May 13, 2011.
x Plaintiff/Defendant: Rebuttal no later than May 27, 2011.
The parties stipulate to and request the Court to order that these deadlines be extended as
x Plaintiff/Defendant: No later than June 3, 2011.
x Plaintiff/Defendant: Rebuttal no later than June 17, 2011.
Expert Discovery Cutoff. The Scheduling Order provides that all expert discovery shall be Dispositive Motions. The Scheduling Order further provides that the last day to file dispositive motions is July 8, 2011. The parties stipulate to and request the Court to order an 3 extension of this date to July 29, 2011. 4
All other pretrial dates shall remain the same.
KARL J. KRAMER MATTHEW S. CHEN EMILY H. SHEFFIELD PETER H. DAY MORRISON & FOERSTER LLP By: MATTHEW S. CHEN Attorneys for Plaintiff JAHIR ALBERTO ROJAS Dated: March 28, 2011 KAMALA D. HARRIS Attorney General of California MICHAEL W. JORGENSON Supervising Deputy Attorney General D. ROBERT DUNCAN Deputy Attorney General EMILY L. BRINKMAN Deputy ...