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Kittrich Corporation, A California Corporation v. Global Glory Industrial Limited

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


October 4, 2012

KITTRICH CORPORATION, A CALIFORNIA CORPORATION, PLAINTIFF,
v.
GLOBAL GLORY INDUSTRIAL LIMITED, A HONG KONG CORPORATION; BIG LOTS STORES, INC., AN OHIO CORPORATION; AND DOES 1-10 INCLUSIVE, DEFENDANTS.

The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge

JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DEADLINES

Pursuant to Civil Local Rule 144 of the United States District Court for the Eastern District of California, Plaintiff Kittrich Corporation ("Kittrich") and Defendant Global Glory 2 Industrial Limited ("Global Glory"), by and through their respective counsel, hereby stipulate 3 and agree to the following:

On or about February 7, 2012, this Court issued a Status (Pretrial Scheduling Order) 5 [Docket No. 27], which provided, among other things, "Each party shall comply with Federal 6 Rule of Civil Procedure 26(a)(2)(B) and (C)'s initial expert witness disclosure requirements on 7 or before October 5, 2012, and any contradictory and/or rebuttal expert disclosure authorized 8 under Rule 26(a)(2)(D)(ii) on or before November 1, 2012."

The parties are currently engaged in serious settlement discussions, and are close to reaching a deal. The parties agree that in the interests of judicial economy, to preserve the parties' resources, and to facilitate settlement discussions, the deadlines from the Status (Pretrial Scheduling Order) [Docket No. 27] should be continued approximately 45 days so that the following deadlines apply:

November 19, 2012: Deadline for each party to comply with Federal Rule of Civil Procedure 26(a)(2)(B) and (C)'s initial expert witness disclosure requirements December 17, 2012: Deadline for any contradictory and/or rebuttal expert disclosure authorized under Rule 26(a)(2)(D)(ii) This is the first stipulation to modify these deadlines. The parties have never obtained an extension on these deadlines.

Respectfully submitted, Dated: October 4, 2012 SNR DENTON US LLP By:____________/S/ Karen C. Marchiano _______ Karen C. Marchiano Attorneys for Plaintiff Kittrich Corporation Dated: October 4, 2012 ELLA CHEONG By:____________/S/ Sam Yip________________ SAM YIP Attorneys for Defendant Global Glory Industrial Limited ATTESTATION CLAUSE I attest under penalty of perjury that the concurrence in the filing of this document has been obtained from its signatories. By:____________/s/ Karen C. Marchiano ___ KAREN C. MARCHIANO

[PROPOSED] ORDER

Pursuant to the parties' stipulation and good cause appearing, it is hereby ordered that the deadlines from the Status (Pretrial Scheduling Order) [Docket No. 27] are continued so that the following deadlines apply:

November 19, 2012: Deadline for each party to comply with Federal Rule of Civil Procedure 26(a)(2)(B) and (C)'s initial expert witness disclosure requirements December 17, 2012: Deadline for any contradictory and/or rebuttal expert disclosure authorized under Rule 26(a)(2)(D)(ii)

IT IS SO ORDERED.

20121004

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