UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
April 8, 2011
RONALD MOORE PLAINTIFF,
COSTCO WHOLESALE CORPORATION D/B/A COSTCO WHOLESLAE
The opinion of the court was delivered by: Gary S. Austin United States Magistrate Judge
K. Randolph Moore (SBN 106933) Tanya E. Moore (SBN 206683) MOORE LAW FIRM, P.C. 332 North Second Street San Jose, California 95112 Telephone: 408-298-2000 Facsimile: 408-298-6046 Attorneys for Plaintiff Ronald Moore CHARLES A. VALENTE (State Bar # 242740) KRASNOW SAUNDERS CORNBLATH, LLP 500 North Dearborn Street, 2nd Floor Chicago, Illinois 60654 (312) 755-5700; Fax: (312) 755-5720 Attorneys for Defendant Costco Wholesale Corporation
JOINT STIPULATION TO EXTEND DATES SET BY SCHEDULING ORDER; ORDER
Plaintiff Ronald Moore, by his undersigned counsel, and Defendant Costco Wholesale Corporation, by its undersigned counsel, jointly stipulate to extend the schedule for various pre-trial dates as follows:
WHEREAS, on November 29, 2011, this Court entered a Scheduling Order setting a schedule for this litigation;
WHEREAS, during the month of February 2011, one of the attorneys with primary responsibility for handling this matter was unexpectedly hospitalized and put through a battery of medical tests;
WHEREAS, the attorney has been diagnosed with a serious disease which will require extensive surgery and several months of treatment. (The parties have been non-specific here to avoid putting personal medical information in the public record. If the Court so desires the specifics can be provided for incamera review.);
NOW, THEREFORE, IT IS HEREBY AGREED AND STIPULATED AS FOLLOWS:
1. In light of the situation, the parties have agreed to stay all discovery until June 24, 2011 and to continue all dates for 90 days as follows:
Complete Fact Discovery April 29, 2011
July 29, 2011
Disclose Experts May 6, 2011 August 8, 2011
Disclose Supplemental Experts May 27, 2011 August 29, 2011
Complete Expert Discovery June 30, 2011 September 30, 2011
Non-Dispositive Motions Filed By August 19, 2011 November 18, 2011
Dispositive Motions Filed by Pre-trial Conference Date October 14, 2011 January 6, 2012 January 13, 2012 April 2012
Trial Date February 28, 2012 June 2012
2. Responses to Plaintiff's pending discovery under Rules 33, 34, and 36 will be due on July 5, 2011.
3. Plaintiff's Inspection of Costco's premises will be continued to June 24, 2011 at 8:30 a.m.
The Parties having so stipulated, and good cause appearing, it is hereby ordered as follows:
1. Discovery in the matter shall be stayed through June 23, 2011;
2. The dates set in the Court's Scheduling Order filed November 29, 2010 shall be continued as follows:
Complete Fact Discovery July 29, 2011
Disclose Experts August 8, 2011
Disclose Supplemental Experts August 29, 2011
Complete Expert Discovery September 30, 2011
Non-Dispositive Motions Filed By November 18, 2011
Dispositive Motions Filed by Pre-trial Conference Date January 13, 2012 April 12, 2012 Trial Date June 5, 2012
3. Responses to Plaintiff's pending discovery under Rules 33, 34, and 36 are due July 5, 2011.
4. Plaintiff's Inspection of Costco's premises will be continued to June 24, 2011 at 8:30 a.m. IT IS SO ORDERED.
IT IS SO ORDERED.
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