KAREN M. GOODMAN SBN: 117423 VIRGINIA CALE SBN: 258557 GOODMAN & ASSOCIATES 3840 Watt Avenue, Building A Sacramento, CA 95821 Telephone No: (916) 643-0600 Facsimile No: (916) 643-0605 firstname.lastname@example.org email@example.com Attorney for Defendants STEVE WRIGHT; CAROL WRIGHT; ALL PROFESSIONAL REALTY, INC.; and ALL PROFESSIONAL HAWAII REALTY, INC.
REVISED STIPULATION AND
[PROPOSED] ORDER TO CONTINUE PRE-TRIAL SCHEDULING DATES
TO THE COURT, ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
Plaintiff Century 21 Real Estate, LLC and Defendants All Professional Realty, Inc., All Professional Hawaii Realty, Inc., Steve M. Wright and Carol Wright, by and through their attorneys of record, stipulate and request that the pre-trial scheduling dates be continued to allow the parties to participate in mediation in good faith before mediator Lori Gualco on April 12, 2012. The dates were previously continued by order Revised Stipulation and Order to Continue Pre-Trial Scheduling Dates Page - 1 Century 21 Real Estate v. All Professional dated February 16, 2012, but the stipulation filed was not the final agreed upon stipulation (due to an error by filing counsel) and failed to account for additional delay based upon the parties' choice of mediator. A subsequent stipulation and order, setting the deadlines out further, was denied without prejudice by Magistrate Judge Gregory G. Hollows.
The request for the continuance is due to the parties' attempt to informally resolve this matter short of trial, through private mediation. The parties desire to participate in mediation, but would like to avoid incurring additional discovery costs at this time while pursuing full resolution of the matter. Based upon the denial of the previous stipulation and order without prejudice, the parties have revised the stipulation to avoid any potential interference with the currently scheduled pretrial conference and trial dates. Therefore, the parties stipulate to the following new and revised pre-trial schedule:
1) The trial date shall remain set for October 30, 2012 at 9:00 a.m. in Courtroom 5;
2) The Final Pretrial Conference shall remain set for August 20, 2012 at 2:00 p.m. in Courtroom 5;
3) The deadline for filing all motions, except motions for continuances, temporary restraining order, or other emergency applications, shall remain set for June 18, 2012;
4) The deadline to complete all discovery (including the resolution of any discovery disputes) shall be continued until June 18, 2012;
5) The deadline to disclose experts and produce reports pursuant to Federal Rule of Civil Procedure 26(a)(2) shall be continued until no later than May 2, 2012;
6) The deadline to disclose rebuttal experts and their reports in accordance with Federal Rule of Civil Procedure 26(a)(2) shall be continued until no later than May 31, 2012.
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