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Ronald Moore v. Costco Wholesale Corporation D/B/A Costco Wholeslae

April 8, 2011

RONALD MOORE PLAINTIFF,
v.
COSTCO WHOLESALE CORPORATION D/B/A COSTCO WHOLESLAE
DEFENDANT.



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:

Current Date

Proposed Date

Complete Fact Discovery April 29, 2011

July 29, 2011

Disclose Experts May 6, 2011 August 8, 2011

Disclose Supplemental Experts May 27, 2011 ...


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