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Bracamontes & Vlasak A Professional Law Corporation v. Clean Harbors Environmental Services

July 20, 2012

BRACAMONTES & VLASAK A PROFESSIONAL LAW CORPORATION CHI NGUYEN,
PLAINTIFF,
v.
CLEAN HARBORS ENVIRONMENTAL SERVICES, INC., ET AL.,
DEFENDANTS.



The opinion of the court was delivered by: Hon. James Ware Chief Judge of the U.S. District Court

STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE PARTIES' EXPERT DISCLOSURE DEADLINES BY 30 DAYS Motion To Be Decided on Papers DEPT: Courtroom 9, 19th Floor JUDGE: Hon. James Ware ACTION FILED: February 18, 2011 TRIAL DATE: None www.bvlawsf.com

IT IS HEREBY STIPULATED AND AGREED by and among all parties that: 20

The parties' deadline to serve and lodge expert witness reports, and all related expert disclosures 21 per Federal Rule of Civil Procedure 26, shall be continued by 30 days. 22

A continuance is required because Defendant has represented that a key witness, Scott Brunn, is 23 currently unavailable and on medical leave. Plaintiff believes Mr. Brunn's testimony is necessary to 24 properly and adequately prepare expert witnesses. Additionally, on July 16, 2012, Defendants 25 produced over 3,000 additional documents. The parties believe review of these previously undisclosed 26 documents is necessary to properly and adequately prepare expert witnesses.

IT IS SO STIPULATED AND AGREED.

DATED: _______________________ ___________________________

Michael R. Bracamontes, Esq. Bracamontes & Vlasak, P.C. Attorneys for Plaintiff DATED: Jamerson C. Allen, Esq. Jackson Lewis, LLP Attorney for Defendant

IT IS SO ORDERED that:

Bracamontes & Vlasak A Professional Law Corporation www.bvlawsf.com

1. The parties shall serve and lodge expert witness reports by September 10, 2012. 14

2. The parties' deadline to file a Motion to Exclude Expert Witnesses shall be September 13, 2012. 15

3. The parties' deadline to disclose rebuttal expert witnesses shall be September 24, 2012. 16

4. The parties' deadline to file a Motion to Exclude Rebuttal Expert Witnesses shall ...


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