United States District Court, E.D. California
H.W.J. DESIGNS FOR AGRIBUSINESS, INC. AND SAMUEL, SON & CO. USA INC., Plaintiff,
RETHCEIF ENTERPRISES, LLC A/K/A RETHCEIF PACKAGING, AND L.P. BROWN COMPANY, INC. D/B/A INTERNATIONAL FIBER PACKAGING, Defendants.
KILPATRICK TOWNSEND & STOCKTON LLP, Steven D. Moore,
Benjamin M. Kleinman, KILPATRICK TOWNSEND & STOCKTON LLP,
Stephen C. Hall, Allison L. Brown, WYATT, TARRANT &
COMBS, LLP, Mark Vorder-Bruegge, Jr, Matthew M. Lubozynski,
WYATT, TARRANT & COMBS, LLP Attorneys for Defendant L.P.
BROWN COMPANY, INC.
De Gyarfas, FOLEY & LARDNER LLP, Michael Houston, Andrew
M. Gross, R. Spencer Montei, FOLEY & LARDNER LLP, Pavan
Agarwal, FOLEY & LARDNER LLP, FOLEY & LARDNER LLP,
Attorneys for Plaintiffs H.W.J. Designs for Agribusiness,
Inc. and Samuel, Son & Co. (USA) Inc.
Eric Gaum, TAFT STETTINIUS & HOLLISTER LLP, Ryan O.
White, TAFT STETTINIUS & HOLLISTER LLP, Jaimin H. Shah,
TAFT STETTINIUS & HOLLISTER LLP, E. Upper Wacker Dr.,
James H. Wilkins, WILKINS, DROLSHAGEN & CZESHINSKI LLP.,
Attorneys for Defendant Rethceif Enterprises, LLC.
JOINT MOTION FOR CONTINUATION OF EXPERT DISCLOSURE
DEADLINES; ORDER (DOC. 163)
K. OBERTO UNITED STATES MAGISTRATE JUDGE.
Parties hereby jointly move the Court to continue the
deadlines for opening and rebuttal expert disclosures. This
request is distinct from the previous joint request regarding
discovery deadlines (Dkt. 146), which the Court graciously
granted (Dkt. 147).
noted when the Parties made that earlier request, the Parties
are working diligently to discharge all remaining discovery
obligations. In particular, the Parties have finalized
logistics for all remaining depositions. In order to meet the
discovery schedule, the Parties “double-tracked”
depositions: depositions (in different locations and of
different witnesses) would be conducted at the same time by
having different members of each side's legal team attend
the double-tracked depositions.
a key member of Defendants' team of counsel has to
unexpectedly confront a series of medical emergencies.
Plaintiff has responded with courtesy and professionalism,
and the Parties have rescheduled the affected depositions.
these rescheduled depositions to be taken into account in the
expert disclosures, the Parties need, and therefore
respectfully request, an additional two weeks to prepare
those disclosures. The Parties also request an associated
continuation of the current deadline for rebuttal expert
disclosures, but to minimize the impact on the overall
schedule the Parties have agreed to compress the time period
to prepare those rebuttal disclosures. The parties request
only a one week extension of that deadline. This is reflected
in the table below. The proposed changes impact neither the
deadlines for the overall completion of expert discovery, the
deadlines for non-dispositive and dispositive motions, nor
the trial date.
Current Deadline (Dkt. 147)
January 13, 2020
January 27, 2020
Rebuttal expert disclosures
February 17, 2020
February 24, 2020
pursuant to E.D. Cal. Local Rule 144(a) and Fed.R.Civ.P. 6,
the Parties seek the Court's approval to continue the
reviewed the Parties' JOINT MOTION FOR CONTINUATION OF
EXPERT DISCLOSURE DEADLINES (Doc. 163), and for good cause
shown (see Fed. R. Civ. P. 16(b)(4)), the Motion is
GRANTED, and the Court MODIFIES the Scheduling Order as
follows: Expert disclosures are now due ...