IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
September 17, 2012
CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION, ET AL DEFENDANTS.
The opinion of the court was delivered by: Edmund F. Brennan United States Magistrate Judge
STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCLOSURE, EXPERT DISCOVERY, AND PRETRIAL MOTION DEADLINES
IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES:
1. Plaintiff, LEON GRAY, is represented by ROBERT N. KITAY of the Law Office of Robert N. Kitay, PC. Defendant, TIMOTHY DAGE, is represented by LYNNE G. STOCKER of Andrada & Associates.
2. Pursuant to a professional courtesy request by Plaintiff's counsel due to having been experiencing some financial stresses over the past couple of months that have required him to divert resources to other areas. As a result of these financial stresses, Mr. Kitay did not have the funds available to pay the expert to produce his report. The expert graciously allowed Mr. Kitay to designate him without pre-payment of funds, but understandably would not do any work until a retainer is paid. Mr. Kitay expects to have the funds to pay the retainer within the next 2-4 weeks. Once that is done, the designated expert will be able to produce his written report.
3. On this basis, the parties have agreed to extend the expert disclosure deadlines, expert discovery deadlines, and pretrial motion deadlines as follows: Expert discovery deadline January 24 9, 2013 Plaintiff's expert disclosure October 24, 2012 Defendant's expert disclosure November 26, 2012 Supplemental expert disclosure December 26 7, 2012 Pretrial motions February 22 20, 2013 (except motions to compel discovery) Final Pretrial Conference April 3, 2013
Dated: LAW OFFICE OF ROBERT N. KITAY,PC ROBERT N. KITAY Attorney for Plaintiff Dated: September 14, 2012 ANDRADA & ASSOCIATES By: LYNNE G. STOCKER Attorneys for Defendant Dage
IT IS SO ORDERED.
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