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Levon Graham v. D. L. Runnels

August 27, 2012

LEVON GRAHAM, PLAINTIFF,
v.
D. L. RUNNELS, ET AL.,
DEFENDANTS.



The opinion of the court was delivered by: Honorable Gregory G. Hollows

LATHAM & WATKINS LLP James L. Day (Bar No. 197158) Brian D. Berry (Bar No. 229893) Brendan K. Kelleher (Bar No. 275883) 505 Montgomery Street, Suite 2000 San Francisco, California 94111-6538 Telephone: .415.391.0600 Facsimile: .415.395.8095 Email: jim.day@lw.com Email: brian.berry@lw.com Email: brendan.kelleher@lw.com Attorneys for Plaintiff Levon Graham Additional Counsel on Signature Block

STIPULATION AND [PROPOSED] ORDER ESTABLISHING SCHEDULE FOR PRETRIAL EXCHANGE OF EXPERT REPORTS AND MODIFYING PRETRIAL CONFERENCE DATE Complaint Filed: October 26, 2007 Trial Date: None

STIPULATION

WHEREAS the Court, in its July 23, 2012 Further Scheduling Order, scheduled the final 3 pretrial conference in this case for January 10, 2013;

WHEREAS, pursuant to Local Rule 281, plaintiff's pretrial statement currently is due to 5 be filed on December 27, 2012, and defendant's pretrial statement and the joint statement of 6 plaintiff and defendant currently are due to be filed on January 3, 2013;

WHEREAS, defendant has designated new trial counsel who is scheduled to start trial on January 7, 2013 in the matter of Fratus v. Peterson (E.D. Cal. No. 1:08-cv-1500 ROS) that will prevent her from attending the pretrial conference on January 10, 2013;

WHEREAS, in addition, counsel for both plaintiff and defendant wish to establish a pretrial schedule for the exchange of any expert reports and/or rebuttal expert reports in this case;

THEREFORE, the parties, through their respective counsel of record, hereby agree and STIPULATE that:

1. The deadline to exchange any expert reports shall be Friday, October 26, 2012;

2. The deadline to exchange any rebuttal expert reports shall be Friday, November 30, 2012;

3. The deadline for completion of any additional expert discovery, including depositions, shall be Friday, December 28, 2012;

4. The deadline for filing all pretrial statements, including plaintiff's, defendant's, and the joint statement, shall be Thursday, January 10, 2013; and

5. The final pretrial conference shall take place on Thursday, ...


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