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Kristine Levitoff v. Thomas J. Vilsack

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


November 29, 2012

KRISTINE LEVITOFF, PLAINTIFF,
v.
THOMAS J. VILSACK, SECRETARY, U.S. DEPARTMENT OF AGRICULTURE, DEFENDANT.

The opinion of the court was delivered by: John A. Mendez United States District Court Judge

STIPULATION REQUESTING MODIFICATION OF SCHEDULING ORDER

Defendant Thomas J. Vilsack, Secretary of the United States Department of Agriculture, and plaintiff Kristine Levitoff, by and through their undersigned counsel, hereby stipulate and agree as follows:

1. On February 13, 2012, the Court entered its Status (Pretrial Scheduling) Order for the case. Docket 14.

2. The scheduling order set the following discovery and motion deadlines:

Plaintiff's Expert Witness Disclosure January 18, 2013 Defendant's Expert Witness Disclosure February 15, 2013 Supplemental/Rebuttal Expert Witnesses March 5, 2013 Joint Mid-Litigation Statement April 5, 2013 Discovery Cutoff April 19, 2013 Dispositive Motions (filed by) June 5, 2013 Dispositive Motions (heard by) July 10, 2013 Joint Pretrial Conference Statement September 6, 2013 Final Pretrial Conference September 13, 2013 Trial Briefs October 7, 2013 Trial October 21, 2013

3. For a number of months, the parties have been engaged in settlement negotiations in an attempt to resolve this case. At this time, the parties wish to attempt to reach a settlement by attending a private mediation. Given counsels' work schedules and their upcoming holiday and vacation schedules, the parties will attempt to schedule private mediation to occur in late January 2013.

4. Because plaintiff's expert witness disclosure deadline is in mid-January, with other dates following thereafter, the parties believe that good cause exists for the Court to modify its scheduling order to accommodate the parties' interest in participating in private mediation. The parties would prefer not to have to incur the substantial time and expense associated with expert and non-expert discovery at this time if it is possible that the case may resolve at mediation.

5. Accordingly, the parties agree to request that the Court modify the scheduling order as follows:

Old Date New Date Plaintiff's Expert Witness Disclosure January 18, 2013 March 1, 2013 Defendant's Expert Witness Disclosure February 15, 2013 March 29, 2013 Supplemental/Rebuttal Expert Witnesses March 5, 2013 April 12, 2013 Joint Mid-Litigation Statement April 5, 2013 April 26, 2013 Discovery Cutoff April 19, 2013 May 15, 2013 Dispositive Motions (filed by) June 5, 2013 Dispositive Motions (heard by) July 10, 2013 Joint Pretrial Conference Statement September 6, 2013 Final Pretrial Conference September 13, 2013 Trial Briefs October 7, 2013 Trial October 21, 2013

6. Since the parties are not asking the Court to modify the dispositive motion, pretrial, or trial dates at this time, the requested modification of the scheduling order will not prejudice either party, and should not negatively impact the Court's schedule for this case.

Respectfully submitted, DATED: November 29, 2012 BENJAMIN B. WAGNER United States Attorney By: /s/ Lynn Trinka Ernce LYNN TRINKA ERNCE Assistant United States Attorney DATED: November 29, 2012 By: /s/ Joseph A. Howell JOSEPH A. HOWELL Attorneys for Plaintiff

ORDER

IT IS SO ORDERED.

John A. Mendez

20121129

© 1992-2012 VersusLaw Inc.



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