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Ercedes Matamoros, Individually and As v. Onald Sosnowski and Does 1-50

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION


March 22, 2012

ERCEDES MATAMOROS, INDIVIDUALLY AND AS
HE REPRESENTATIVE OF THE ESTATE OF JUAN MATAMOROS, PLAINTIFFS,
v.
ONALD SOSNOWSKI AND DOES 1-50 DEFENDANTS.

STIPULATION TO MODIFY STATUS (Pre-Trial) SCHEDULING ORDER RE s. EXPERT DISCLOSURE AND DISCOVERY CUT-OFF DATES ORDER THEREON

Whereas, the Complaint in this matter was filed in June of 2011; and Whereas, the trial in this matter is currently set for September 24, 2012; and Whereas, the parties through their counsel of record anticipate that no dispositive motions will be filed in this matter; and Whereas attorneys Douglas Gessell for plaintiff and Peter Cuttitta for defendant have met and conferred regarding the scheduling of the expert witness disclosure and discovery cut-off dates.

Therefore, the Parties, by and through their attorneys, and pursuant to the provisions of F.R.C.P. 26 (a), stipulate to modify the Court's October 21, 2011 Status (Pre-Trial) Scheduling Order as follows:

1. The previously ordered expert witness disclosure and discovery cut-off dates shall be vacated, and the following dates shall be substituted:

Expert Witness Disclosure: June 1, 2012 Supplemental Expert Disclosure: June 20, 2012 Discovery Cut-Off (non-expert): July 2, 2012 Discovery Cut-Off (expert): July 16, 2012 2. The expert witness disclosure requirements of F.R.C.P. 26(a)(2)(B) shall not be followed in this case, and all such disclosures shall be governed by the provisions of F.R.C.P.26(a)(2)(C); further at the same time as they make their expert disclosures the parties shall also exchange each expert's curriculum vitae and fee schedule. 3. The date for the filing of the parties Joint Mid-Litigation Statement shall be controlled by the above discovery cut-off date.

Dated: March 15, 2012 LAW OFFICES OF BROWN & GESSELL By: /s DOUGLAS A. GESSELL Attorney for Mercedes Matamoros Dated: March 15, 2012 PORTER SIMON By:/s/ PETER CUTTITTA Attorney for Ronald Sosnowski

ORDER

Good cause appearing therefore, IT IS SO ORDERED.

Date: 3/22/2012 /s/ John A. Mendez_____________ JOHN A. MENDEZ United States District Court Judge

20120322

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