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Hollynn D'lil v. Riverboat Delta King

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


October 16, 2012

HOLLYNN D'LIL,
PLAINTIFF,
v.
RIVERBOAT DELTA KING, INC.; CITY OF SACRAMENTO, OLD SACRAMENTO
BUSINESS ASSOCIATION, INC., AND DOES 1 THROUGH 50, INCLUSIVE
DEFENDANTS.

Civil Rights STIPULATION AND [Proposed] ORDER TO EXTEND SCHEDULING ORDER DATES

1 TO THE COURT: 2 The parties request that the Court grant an extension of all dates in the 3 current trial scheduling order by approximately 105 days to accommodate the 4 ongoing discovery. The parties have been diligently working to obtain 5 documents from various City and State governmental agencies. Due to the 6 nature of the Delta King as a floating vessel and the years in which the 7 conversion of the Delta King from a floating vessel to a hotel occurred, the 8 parties have had difficulty in locating and identifying the necessary documents 9 and State and City agencies involved. The parties have also had difficulty locating the necessary parties involved with the City and State governmental agencies some of whom have long ago retired and moved out of state. The parties are in the midst of obtaining additional documents from various City and State agencies, including the City of Sacramento, Sacramento Housing and Redevelopment Agency and the State of California, Office of Historic Preservation. These additional documents are necessary and important to obtain in order to have a complete record before completing discovery and completing depositions, which depositions have been scheduled to occur at the end of this month. The information is also valuable for the experts to review and include in the expert disclosures that are due.

Wherefore, the parties request that the court extend the scheduling order dates as follows:

Deadlines and Dates Current Proposed Expert Disclosures With Reports Oct. 15, 2012 January 28, 2013 Completion of Discovery and Hear Discovery Motions January 7, 2013 April 22, 2013 File all motions except continuances and TROs April 9, 2013 July 23, 2013 File Separate Pretrial Conf. Statements Plaintiff: June 10, 2013 Defendant: June 17, 2013 Plaintiff: Sept. 23, 2013 Defendant: Sept. 30, 2013 Final Pretrial Conference June 24, 2013, 2 PM Oct. 15, 2013, 2:00 PM Trial (5 Days) Aug. 20, 2013, 9 AM Dec. 3, 2013, 9:00 AM

4 IT IS SO STIPULATED:

Dated: October 12, 2012 weintraub tobin chediak coleman grodin LAW CORPORATION By: /s/ Donna L. Holtz Donna L. Holtz Attorneys for Defendant Riverboat Delta King, Inc. THIMESCH LAW OFFICES By: /s/ Timothy S. Thimesch Timothy S. Thimesch Attorneys for Plaintiff HOLLYNN D'LIL Dated: October 12, 2012 SANDRA G. TALBOTT, Interim City Attorney KATHLEEN T. ROGAN, Sr. Deputy By: /s/ Kathleen T. Rogan Kathleen T. Rogan Attorneys for Defendant CITY OF SACRAMENTO Dated: October 12, 2012

1 ORDER

2 Pursuant to the stipulation of the parties as set forth above, and good 3 cause appearing therefore, IT IS SO ORDERED.

20121016

© 1992-2012 VersusLaw Inc.



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