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Levon Graham v. D. L. Runnels

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION JUDICIAL DISTRICT


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, January 17, 2013.

[PROPOSED] ORDER

The final pretrial conference currently scheduled for January 10, 2013, is hereby 3 rescheduled for January 17, 2013. The deadline for all parties to file separate and joint pretrial 4 statements is January 10, 2013. The deadline for the parties to exchange expert reports is 5 October 26, 2012. The deadline for the parties to exchange any rebuttal expert reports is 6 November 30, 2012. The deadline for completion of all expert discovery is December 28, 2012.

The jury trial remains set for February 25, 2013, at 9:00 a.m.

IT IS SO ORDERED.

Gregory G. Hollows

20120827

© 1992-2012 VersusLaw Inc.



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