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Sonoma Tires, Inc., A California v. Big O Tires

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


July 13, 2012

SONOMA TIRES, INC., A CALIFORNIA
CORPORATION,
PLAINTIFF,
v.
BIG O TIRES, LLC, A COLORADO LIMITED LIABILITY COMPANY, DEFENDANT.

The opinion of the court was delivered by: The Honorable Richard Seeborg

STIPULATION REGARDING LITIGATION DEADLINES AND [PROPOSED] ORDER [L.R. 7-12]

Big O Tires, LLC ("Big O"), on the one hand, and Sonoma Tires, Inc. ("Sonoma") and John G. Rhiel, IV ("Rhiel"), on the other hand, (collectively, "Parties") by and through their 27 respective undersigned counsel, hereby stipulate and jointly request that the Court issue an Order 28 as follows:

Stipulation Regarding Litigation Deadlines and [Proposed] Order;

WHEREAS, the parties current deadline to complete non-expert depositions is July 16, 2012;

WHEREAS, the parties have completed some but not all non-expert depositions in this 4 matter; 5

WHEREAS, the parties have met and conferred and, due to scheduling issues, desire to 6 complete all discovery, including depositions, by on or before August 3, 2012; 7

WHEREAS, the current scheduling order, as modified by the Court's May 4, 2012 Order, 8 provides adequate time to allow for the requested modification without extending the trial date; 9

IT IS THEREFORE STIPULATED AND JOINTLY REQUESTED that:

1. The Court order that the parties shall have up to and including August 3, 2012 to complete non-expert discovery, including non-expert depositions;

2. The Court order that the parties shall have up to and including October 11, 2012 to have heard all pretrial motions, including but not limited to any motion for summary judgment and/or summary adjudication; and

3. All other deadlines remain as set forth the Court's scheduling order.

IT IS SO STIPULATED.

SEYFARTH SHAW LLP Dated: July 13, 2012 By /s/ Joseph J. Orzano Joseph J. Orzano Attorneys for Big O Tires, LLC LAGARIAS & BOULTER, LLP Dated: July 13, 2012 By /s/ Peter C. Lagarias_ Peter C. Lagarias Attorneys for Sonoma Tires, Inc. and John G. Rhiel, IV

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED,

1. The parties shall have up to and including August 3, 2012 to complete non-expert 4 discovery, including non-expert depositions;

2 All pretrial motions shall be heard no later than October 11, 2012; and 6

3. All other deadlines remain as set forth in the Court's scheduling order. 7 8

20120713

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