STIPULATION AND PROPOSED ORDER TO MODIFY SCHEDULING ORDER Honorable William B. Shubb Trial: April 16, 2013 STIPULATION
The parties, Plaintiff Federal Deposit Insurance Corporation as Receiver for IndyMac Bank, F.S.B. and Defendants Richard Varrasso, Premier Valley Inc. dba Century 21 M&M Associates, and Karen Bhatti by and through their counsel of record or personally hereby stipulate and agree to modify the Pretrial Scheduling Order in this matter to extend the expert disclosure and discovery cutoff dates. The Parties agree to extend the deadline for the disclosure of expert witnesses and rebuttal witness by thirty days in order to accommodate the calendar of Plaintiff's expert. In light of the fact that the new disclosure deadline would coincide with the close of discovery, the parties also seek a thirty day extension in which to complete discovery.
The current due dates for disclosure of initial experts and rebuttal experts are August 31, 2012 and September 28, 2012, respectively. The deadline for completion of discovery is currently October 26, 2012. The parties stipulate to the dates of September 28, 2012 for the initial disclosure and October 26, 2012 for the rebuttal disclosure. They further stipulate to extend the discovery deadline to November 30, 2012.
No other provision of the Pretrial Scheduling Order is to be modified.
DATED: August 30, 2012 GCA LAW PARTNERS LLP By:___/s/ Susan Condon__________ SUSAN CONDON Attorney for Plaintiff FEDERAL DEPOSIT INSURANCE CORPORATION as RECEIVER for INDYMAC BANK, F.S.B. DATED: August 30, 2012 TRIEBSCH & FRAMPTON By:___/s/ Cory B. Chartrand_____ CORY B. CHARTRAND Attorneys for Defendants, PREMIER VALLEY, INC., DBA CENTURY 21 M&M AND ASSOCIATES, and KAREN BHATTI (as Authorized on August 30, 2012)
DATED: August 30, 2012 Richard Varrasso Richard Varrasso Appearing Pro Se
(as Authorized on August 30, 2012)
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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