Opinion
CASE NO. CV11 1668 DMR
11-23-2011
GANG CHEN, Plaintiff, v. BMW OF NORTH AMERICA, LLC, AND DOES 1 THROUGH DOE 10, INCLUSIVE, Defendants.
THE BICKEL LAW FIRM, INC. By: Michael Devlin, Esq. Attorneys for Plaintiff GANG CHEN LEWIS BRISBOIS BISGAARD & SMITH LLP By: Roger S. Raphael, Esq. William P. Buranich, Esq. Attorneys for Defendant BMW OF NORTH AMERICA, LLC
ROGER S. RAPHAEL, SB# 111946
WILLIAM BURANICH, SB# 144650
LEWIS BRISBOIS BISGAARD & SMITH LLP
Attorneys for Defendant BMW OF NORTH
AMERICA, LLC
STIPULATION AND Revised ORDER TO EXTEND DISCOVERY COMPLETION DATE
Plaintiff GANG CHEN ("CHEN") and defendant BMW of NORTH AMERICA, LLC "(BMW NA") through their respective attorneys of record, hereby stipulate as follows:
WHEREAS, at the initial Case Management Conference the Court set a discovery completion date of December 27, 2011;
WHEREAS, although the parties have acted diligently in attempting to complete discovery, they have not be been successful;
WHEREAS, due to a personal family matter, counsel for BMW NA, William Buranich, was previously unavailable and counsel for plaintiff CHEN, Michael Devlin, has only recently been assigned to the file;
WHEREAS, the court has previously continued the mediation completion date to January 11, 2012, and the trial date is currently May 14, 2012;
WHEREAS, CHEN and BMW NA request that this Court continue the current discovery completion date March 1, 2012.
THEREFORE IT IS STIPULATED by and between CHEN and BMW NA that the deadline for completion of discovery is extended from December 27, 2011 to March 1, 2012.
This Stipulation may be signed in counter-parts, each counter-part having the same force and effect as originals, and facsimile signatures shall be deemed to have the same force as originals.
THE BICKEL LAW FIRM, INC.
By: Michael Devlin, Esq.
Attorneys for Plaintiff GANG CHEN
LEWIS BRISBOIS BISGAARD & SMITH LLP
By: Roger S. Raphael, Esq.
William P. Buranich, Esq.
Attorneys for Defendant BMW OF NORTH
AMERICA, LLC
ORDER
IT IS ORDERED, based upon the stipulation of the parties that the deadline to complete discovery in this matter is continued from December 27, 2011 to March 1, 2012.
All other case management dates shall remain the same.
By Donna M. Ryu
Magistrate Judge of the
United States District Court