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Linde, LLC v. Valley Protein, LLC

United States District Court, E.D. California

June 27, 2017

LINDE, LLC, Plaintiff,
v.
VALLEY PROTEIN, LLC,, and DOES 1 to 10; Defendants.

          Russell K. Ryan, MOTSCHIEDLER, MICHAELIDES, WISHON, BREWER & RYAN, LLP Attorneys for Defendant Valley Protein, LLC.

          McGLINCHEY STAFFORD, Adam S. Hamburg, Attorneys for Plaintiff LINDE, LLC.

          JOINT STATUS REPORT RE REQUEST FOR EXTENSION OF DISCOVERY DEADLINES AND DEADLINE TO FILE DISPOSITIVE MOTIONS; DECLARATIONS OF COUNSEL IN SUPPORT THEREOF; ORDER THEREON

         Pursuant to the Court's Scheduling Order Setting Status Conference, Plaintiff Linde, LLC (“Plaintiff”) and Defendant Valley Protein, LLC (“Defendant”) respectfully submit this Joint Status Report.

         I

         REQUESTED EXTENSIONS

Current Deadline

New Deadline

Non Expert Discovery Cutoff

06/16/17

09/15/17

Expert Disclosure

07/17/17

10/17/17

Rebuttal Expert Disclosure

08/17/17

11/17/17

Expert Discovery Cutoff

09/18/17

12/18/17

Dispositive Motion Deadline

11/01/17

02/02/17

         II

         DISCOVERY TO DATE

         Both parties have engaged in initial disclosures and extensive written discovery, with recent requests geared toward the recently filed counterclaim, the allegations contained therein and the affirmative defenses alleged in the answers to the complaint and the counterclaim. Both parties have produced extensive documents related to the various claims and defenses asserted in the matter, which has taken substantial time to review and analyze.

         Further, the parties recently participated in nearly a full-day early settlement conference before this court, and have al all times worked cooperatively to streamline discovery and attempt to resolve the dispute without extensive costs in discovery.

         III

         DISCOVERY TO BE COMPLETED

         A. Linde, LLC

         Plaintiff is awaiting responses to outstanding written discovery. It agreed to an extension which makes Defendant's responses due the week of June 26th. After Plaintiff receives and reviews the complete responses to its outstanding written discovery, it needs to depose ...


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