Opinion
Case No.: 3:07-CV-04263-JSW
10-31-2011
SHEIK ZAHID ALI and SAFIYA ZAYNA ALI, Plaintiffs, v. TRIMAC TRANSPORTATION SERVICES (WESTERN), INC.; COLUMBIA PAINT & COATINGS and DOES 1 to 100, Defendants.
MARANGA • MORGENSTERN A Professional Law Corporation ROBERT A. MORGENSTERN CHRISTOPHER F. JOHNSON RICHARD M. OZOWSKI Attorneys for Defendant TRIMAC TRANSPORTATION SERVICES (WESTERN), INC. ANDERLINI & EMERICK LLP MERRILL G. EMERICK Attorneys for Plaintiffs SHEIK ZAHID ALI And SAFINA ZAYNA ALI
ROBERT A. MORGENSTERN, ESQ. (SBN 94180)
CHRISTOPHER F. JOHNSON, ESQ. (SBN 114177)
RICHARD M. OZOWSKI, ESQ. (SBN 219226)
MARANGA • MORGENSTERN
A Professional Law Corporation
Attorneys for Defendants,
TRIMAC TRANSPORTATION SERVICES (WESTERN), INC. and
ROHM AND HAAS COMPANY
STIPULATION TO EXTEND
DISCOVERY PERIOD
AND ORDER THEREON
Pursuant to Local Rule 6-1(a), Plaintiffs SHEIK ZAHID ALI and SAFIN A ZAYNA ALI and Defendant TRIMAC TRANSPORTATION SERVICES (WESTERN), INC. ("Trimac") hereby stipulate to extend the discovery period, as follows:
On or about July 1, 2011, the Court issued a Civil Minute/Scheduling Order following a Case Management Conference of the same date. Among other things, the Court ordered the close of all fact discovery on November 7, 2011.
As litigation has progressed, the parties mutually have concluded that additional time is warranted to fully explore the issues necessary to adequately prepare for trial or alternate resolution. Among other things: (a) difficulties have arisen in obtaining insurance underwriting records, particularly from foreign jurisdictions such as Canada and (b) securing the depositions of witnesses likewise located in foreign jurisdictions. Therefore, the parties hereby stipulate and agree to extend the close of fact discovery, for all purposes, to December 1, 2011. Pursuant to their signatures below, Counsel for Plaintiffs and Trimac evidence their stipulation as herein set forth.
MARANGA • MORGENSTERN
A Professional Law Corporation
ROBERT A. MORGENSTERN
CHRISTOPHER F. JOHNSON
RICHARD M. OZOWSKI
Attorneys for Defendant
TRIMAC TRANSPORTATION
SERVICES (WESTERN), INC.
ANDERLINI & EMERICK LLP
MERRILL G. EMERICK
Attorneys for Plaintiffs SHEIK ZAHID ALI
And SAFINA ZAYNA ALI
Jeffrey S. White