United States District Court, N.D. California
DAN SIEGEL SBN 56400, JANE BRUNNER SBN 135422, NEIL COLIN SATTERLUND, SBN 28673, SIEGEL & YEE, Oakland, California, Attorneys for Plaintiff SUSAN RILEY.
Carl L. Fessenden, Katherine L.M. Mola, PORTER SCOTT, Attorney for Defendant Board of Trustees of the California State University.
STIPULATION AND [PROPOSED ORDER] TO EXTEND DISCOVERY CUT-OFF AND PRETRIAL MOTIONS
RICHARD SEEBORG, District Judge.
The parties, by and through their counsel of record, stipulate and agree as follows:
The parties have been engaged in meet and confer efforts regarding Request for Production of Documents, Set One, served to Defendant Board of Trustees of the California State University on October 17, 2013, and responded to by Defendant on December 6, 2013.
The parties have a mediation set for February 4, 2014.
The Court set April 11, 2014 for all non-expert discovery to be completed May 9, 2014 for parties to designate experts; May 30, 2014 for all discovery of expert witnesses to be completed; and all Dispositive pretrial motions to be filed and served by July 24, 2014.
The parties have entered into discussions regarding discovery but, given there is a mediation on February 4, 2014, the parties agreed to wait until the mediation is completed to determine if there needs to be further discussions regarding the production of documents and if they need to file a joint letter regarding any discovery disputes.
The parties have agreed to and request the Court modify the Case Management Scheduling Order as follows:
(a) All non-expert discovery shall be completed on or before July 14, 2014;
(b) The parties shall designate experts in accordance with FRCP 26(a)(2) on or before August 11, 2014;
(c) The parties shall designate their supplemental and rebuttal experts in accordance with FRCP 26(a)(2) on or before September 2, 2014;
(d) The parties shall complete all expert witness discovery pursuant to FRCP 26(b)(4) on or ...