The opinion of the court was delivered by: Hon. Susan Illston United States District Court Judge
STIPULATION AND [PROPOSED] ORDER MODIFYING CERTAIN EXPERT DISCOVERY DEADLINES
WHEREAS, on May 4, 2011, the Court issued an order setting certain deadlines related to expert discovery, a copy of which is attached hereto as Exhibit A;
WHEREAS, the parties subsequently, by letter agreement, agreed to extend the deadline for plaintiffs' expert designations to May 31, 2011;
WHEREAS, in light of scheduling issues, the parties have agreed to further modify the cutoff and designation dates related to certain remaining expert discovery;
WHEREAS, such modifications will not affect any other dates set by the Court;
IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 6-1(b), 6-2(a), and 7-12 by and between the undersigned counsel for the Parties that:
1. Pursuant to Civil L.R. 6-2(a), the cutoff and designation dates related to certain expert discovery, set per the Court's Order of May 5, 2011, be further modified as follows:
(a) Defendants' Designation of Experts will move to June 27,2011;
(c) Plaintiffs' Expert Rebuttal will move to July 14, 2011;
(d) Expert Discovery Cutoff will move to August 1, 2011.
2. All other dates set pursuant to the Court's Pretrial Preparation Order of October 27, 2010 shall remain in place.
Dated: June 17, 2011 KERSHAW, CUTTER, & RATINOFF LLP CLARK & MARKHAM LLP LAW OFFICES OF BARRON E. RAMOS CHARLES E. AMES, P.C. THE CROSLEY LAW FIRM, P.C. WEXLER WALLACE LLP By: Stuart C. Talley Attorneys for Plaintiffs HAIDEE ESTRELLA and ANGELICA ARITA Dated: June 17, 2011 FENWICK & WEST LLP 25 By: Kevin P. Muck Attorneys for Defendants FREEDOM FINANCIAL NETWORK, LLC, FREEDOM DEBT RELIEF, INC. and FREEDOM DEBT RELIEF, LLC Dated: June 17, 2011 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP By: Allen Ruby Attorneys for Defendants BRADFORD STROH and ANDREW HOUSSER Dated: June 17, 2011 GREENSPOON MARDER, P.A. 6 By: Richard W. Epstein Attorneys for Defendants GLOBAL CLIENT SOLUTIONS, LLC and ROCKY MOUNTAIN BANK &TRUST Pursuant to General Order No. 45 Section X(B), all of the signatories concur in the filing of this stipulation. 11 12 Dated: June 17, 2011 FENWICK & WEST LLP By: Jennifer C. Bretan
[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT:
1. Pursuant to Civil L.R. 6-2(b), the cutoff and designation dates related to certain expert discovery, set per the Court's Order of May ...