The opinion of the court was delivered by: The Honorable Michael J. Seng U.S. Magistrate Judge
Additional Counsel listed on Page Two
AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES
Action filed: December 29, 2009
TO THE HONORABLE COURT AND TO ALL PARTIES OF AND COUNSEL OF RECORD:
The parties stipulate that the current deadlines be extended for good cause, namely the need for more time to complete outstanding discovery and dispositive motions in an effective manner following the currently pending order of Judge Michael Seng regarding discovery of financial information. The parties have engaged in mediation in this matter and are continuing related discussions.
In good faith and by agreement of the parties, through counsel undersigned, it is respectfully requested that a revised scheduling order be entered to reflect the following stipulated deadlines:
1. The deadline for completing discovery shall be January 30, 2012;
2. The settlement conference shall take place on January 30, 2012 [no change];
3. The deadline for filing dispositive motions shall be February 28, 2012; 4 The expert disclosure deadline shall be February 28, 2012 [no change]; 5. The expert discovery deadline shall be March 30, 2012 [no change]; 6. The pretrial conference shall take place on or after April 13, 2012 [no change]; 7. The trial date shall be continued toJune 12, 2012 at 8:30 am in Courtroom 2 [no change].
These deadlines shall not be amended without further Order of the Court.
This stipulation and the proposed order are submitted in good faith and not for the purpose of delay.
This Stipulation may be signed in counter-parts, each counter-part having the same force and effect as originals, and facsimile signatures shall be deemed to have the same force as originals.
DATED: December 23, 2011 LEWIS BRISBOIS BISGAARD & SMITH LLP By: /s/ Jeffrey S. Ranen Jeffrey S. Ranen Alexander J. Harwin Attorneys for Defendant GIUMARRA VINEYARDS CORPORATION DATED: December 20, 2011 CALIFORNIA RURAL LEGAL ASSISTANCE, INC. By: /s/ Megan Beaman Megan Beaman Attorney for Plaintiff-Intervenors Maribel Ochoa, Delfina Ochoa, Jose Ochoa DATED: December 20, 2011 MARCOS CAMACHO, A LAW CORP. By: /s/ Mario Martinez ...