The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge
ANDREW T. CAULFIELD, SBN 238300 RICHARD H. CAULFIELD, SBN 50258 CAULFIELD LAW FIRM 1101 Investment Blvd., Suite 120 El Dorado Hills, CA 95762 Telephone: (916) 933-3200 Facsimile: (916) 605-4075 firstname.lastname@example.org EDWARD KNAPP, SBN 71520 EL DORADO COUNTY OFFICE OF COUNTY COUNSEL 330 Fair Lane Placerville, CA 95667 Telephone: (530) 621-5770 Facsimile: (520) 621-2937 Attorneys for Defendant/Counterclaimant/Cross-Claimant El Dorado County Fair Association, Inc.
STIPULATION AND PROPOSED ORDER RE EXTENSION OF DISCOVERY MOTION CUT-OFF DATE Trial Date: March 26, 2013
All Parties, by and through their undersigned counsel, hereby stipulate to the following:
1.WHEREAS, on July 19, 2012, upon stipulation of the Parties, the Court modified certain dates in its original Pretrial Scheduling Order. The discovery cut-off was moved from August 15, 2012 to October 15, 2012. The last day for a motion hearing was moved from October 1, 2012 to December 3, 2012. The final pretrial conference was moved from December 1, 2012 to February 4, 2013. (Dckt. No. 124).
2.WHEREAS, the original Pretrial Scheduling Order requires that all discovery disputes be resolved by the discovery cut-off date. (Dckt. No. 57).
3.WHEREAS, the Parties desire to include discovery motions in the previously ordered December 3, 2012 last day for a hearing date.
4.WHEREAS, to the extent that any discovery motion, to be heard on or before December 3, 2012, results in an order allowing additional discovery, the Parties agree that any such Court ordered discovery will be allowed despite the expiration of the discovery cut-off date.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
1. The last day for a discovery motion hearing is December 3, 2012.
2. To the extent that any discovery motion, to be heard on or before December 3, 2012, results in an order allowing additional discovery, any such court ordered discovery will be allowed despite the expiration of the discovery cut-off date.
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