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David Rey v. C&H Sugar Company

June 12, 2012

DAVID REY,
PLAINTIFF,
v.
C&H SUGAR COMPANY, INC., A DELAWARE CORPORATION, AMERICAN SUGAR REFINING, INC., A DELAWARE CORPORATION, AND DOES 1-100, INCLUSIVE,
DEFENDANT.



STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL DATES

The parties hereby stipulate and agree as follows:

WHEREAS; the parties took longer than expected to complete the electronically stored

party vendor.

WHEREAS; the parties have agreed to mediate this matter and would like to do so before incurring expense to prepare and oppose motions for summary judgment. 4

WHEREAS; Plaintiffs would like to complete the depositions of third-party witnesses Francine Cronin and Kim Merritt prior to participating in mediation. 6

THE PARTIES HEREBY AGREE AND REQUEST a continuance of the pre-trial dates as follows:

Dispositive motions:

x Filed by: August 31, 2012

x Opp. due by: September 14, 2012

x Reply due by: September 21, 2012

x Set for hearing no later than: October 5, 2012 at 9:00 a.m.

Non-Expert Discovery cutoff: October 8, 2012

Expert designation: August 17, 2012

Rebuttal expert designation: ...


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