Opinion
Case No. 2:11-CV-02483-MCE-DAD
02-15-2013
AMEDEE GEOTHERMAL VENTURE I, A CALIFORNIA LIMITED PARTNERSHIP, Plaintiff, v. LASSEN MUNICIPAL UTILITY DISTRICT, Defendant.
Robert M. Mitchell (SBN 59756) Craig A. Diamond (SBN 89361) Jamie L. Hogenson (SBN 243447) Diamond ? Baker ? Mitchell, LLP Michael W. Keane (SBN 220685) Woodburn and Wedge Attorneys for Plaintiff AMEDEE GEOTHERMAL VENTURE I, A CALIFORNIA LIMITED PARTNERSHIP
Robert M. Mitchell (SBN 59756)
Craig A. Diamond (SBN 89361)
Jamie L. Hogenson (SBN 243447)
Diamond ? Baker ? Mitchell, LLP
Michael W. Keane (SBN 220685)
Woodburn and Wedge
Attorneys for Plaintiff
AMEDEE GEOTHERMAL VENTURE I,
A CALIFORNIA LIMITED PARTNERSHIP
AMENDED
STIPULATION AND ORDER TO
CONTINUE THE DATE FOR EXPERT
WITNESS DISCLOSURES
Plaintiff, Amedee Geothermal Venture I ("AGVI"), and Defendant, Lassen Municipal Utility District ("LMUD"), by and through their respective undersigned counsel, hereby stipulate and agree and seek leave pursuant to Rule 16(b) of the Federal Rules of Civil Procedure and this Court's Pretrial Scheduling Order filed on March 6, 2012 (hereinafter the "Scheduling Order"), to extend the date for disclosure of expert witnesses, as follows :
1. Pursuant to the Scheduling Order, initial expert designations were due on February 21, 2013, and rebuttal expert designations were due within twenty (20) days after the initial designation of expert witnesses. On December 5, 2012, the Court granted the Parties request, pursuant to a Stipulation and Order, to extend the date for initial expert designations by one week, from February 21, 2013 to February 28, 2013. The Parties hereby agree to further extend the date for initial expert designations in the Scheduling Order from the modified date of February 28, 2013 to March 15, 2013. The Parties also agree that the Parties will have twenty (20) days after the initial designation of expert witnesses within which to provide a supplemental list of expert witnesses for rebuttal purposes only as set forth in Section V of the Scheduling Order.
2. Good cause exists for modification of the Scheduling Order as requested herein in order to provide enough time for the Parties to compose complete expert designations following the close of non-expert discovery, to allow the retained expert witnesses sufficient time to review all of the evidence, as non-expert discovery will not close until February 15, 2013 and there are numerous depositions set to take place between now and then, and, in light of the current outstanding discovery that will be completed in the next several weeks, to provide the experts with sufficient time to prepare their opinions and expert witness reports as required by the Court's Scheduling Order so that meaningful expert discovery may take place.
DIAMOND ? BAKER ? MITCHELL, LLP
By: __________________
Robert M. Mitchell
California State Bar No. 59756
Diamond ? Baker ? Mitchell, LLP
Attorneys for Amedee Geothermal Venture I,
a California Limited Partnership
DOWNEY BRAND LLP
By: Monica S. Hans (as authorized
on February 6, 2013)
Monica S. Hans
California State Bar No. 227379
Cassandra M. Ferrannini
California State Bar No. 204277
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Attorneys for Lassen Municipal Utility District
ORDER
IT IS SO ORDERED.
______________________
MORRISON C. ENGLAND, JR., JUDGE
UNITED STATES DISTRICT JUDGE