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Rosa Ayala, Natalia Madrigal v. Silver Legacy Hotel and Resorts

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


January 13, 2012

ROSA AYALA, NATALIA MADRIGAL,
FABIAN MADRIGAL, STEVE AND KIMBERLEE HEINRICH, PLAINTIFFS,
v.
SILVER LEGACY HOTEL AND RESORTS, KONE INC., DEFENDANTS.

The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

Michael J. Danner (SBN 79269) DANNER &CHONOLES,L.L.P. 6101 Ball Road, Suite 302 Cypress, CA 90630 Telephone: (714) 828-9909 Facsimile: (714) 828-9979 Attorneys for Defendants, KONE INC. AND THE CIRCUS AND ELDORADO JOINT VENTURE, A NEVADA GENERAL PARTNERSHIP DBA THE SILVER LEGACY RESORT CASINO RENO ERRONEOUSLY SUED AS SILVER LEGACY HOTEL AND RESORTS

STIPULATION AND [PROPOSED] ORDER FOR MODIFICATION OF STATUS (PRETRIAL SCHEDULING) ORDER TO EXTEND DEADLINE FOR EXPERT DISCLOSURES

COMES NOW Plaintiffs ROSA AYALA, NATALIA MADRIGAL, FABIAN MADRIGAL, STEVE and KIMBERLEE HEINRICH, by and through their attorney of record, Eduardo A. Gonzalez of David Allen & Associates and Defendants, KONE INC. and THE CIRCUS AND ELDORADO JOINT VENTURE, by and through their attorney, Michael J. Danner of Danner & Chonoles, L.L.P., (collectively all referred to herein as the "Parties") and hereby stipulate as follows:

Whereas, pursuant to the Court's Pretrial Scheduling Order, the deadline for initial expert witness disclosures pursuant to Federal Rule of Civil Procedure 26 (a) (2) (B) and (C) has been set for April 19, 2012 and the deadline for contradictory and/or rebuttal expert disclosures authorized under Rule 26 (a) (2) (D) (ii) has been set for May 18, 2012 and the Parties agree that additional time is necessary to conduct discovery and identify appropriate expert witnesses.

THEREFORE, the Parties now stipulate to continue the deadline for initial expert witness disclosures from April 19, 2012 to June 19, 2012 and to continue the deadline for contradictory and/or rebuttal expert disclosures from May 18, 201 to July 18, 2012. The Parties respectfully request that these deadlines be ordered extended by the Court accordingly.

ORDER

Pursuant to the Stipulation of the Parties hereto, the Pretrial Scheduling Order is modified as follows on page 3, lines 9 - 13:

"Each party shall comply with Federal Rule of Civil Procedure 26(a)(2)(B) and (C)'s initial expert witness disclosure requirements on or before June 19, 2012, and any contradictory and/or rebuttal expert disclosures authorized under Rule 26(a)(2)(d)(ii) on or before July 18, 2012."

20120113

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