Opinion
Case No. 2:11-CV-00041-GEB-JFM
01-05-2012
CAROLINA NAVARRO Plaintiff(s), v. TARGET CORPORATION and DOES 1 through 50 Defendant(s).
Michael R. Mordaunt, Esq., Bar No. 66911 RIGGIO MORDAUNT & KELLY A Professional Law Corporation Attorneys for Defendant TARGET CORPORATION LAW OFFICE OF OMAR GONZALEZ Steven Wanderer, Esq. Attorney for Plaintiff CAROLINA NAVARRO
Michael R. Mordaunt, Esq., Bar No. 66911
RIGGIO MORDAUNT & KELLY
A Professional Law Corporation
Attorneys for Defendant
TARGET CORPORATION
STIPULATION FOR DISCLOSURE OF
WITNESSES & COMPLETION OF
DISCOVERY AND PROPOSED ORDER
WHEREAS the parties have completed initial discovery in the case but have not been successful in completing all of the discovery necessary for the disclosure of experts. One of the witnesses has only recently returned to the State of California and is now available for deposition in the month of January. In addition, the plaintiff remains being treated by her orthopedist at Kaiser and the deposition of the Kaiser physician is scheduled for January 24. Once the depositions listed above have been completed, the parties need an opportunity to consider the issues and retain those experts necessary to respond to both the liability and damage issues resulting from the depositions.
THEREFORE, it is hereby stipulated and agreed that mutual disclosure of expert witnesses and exchange of expert report shall take place on or before March 20, 2012 and the mutual disclosure of rebuttal expert witnesses and exchange of reports shall take place on or before April 20, 2012.
IN ADDITION, the parties hereby stipulate and agree that the discovery cut-off date of March 12, 2012 be extended to May 12, 2012.
The parties request that the trial date currently scheduled for October 9, 2012 remain in place.
LAW OFFICE OF OMAR GONZALEZ
By: _________________________
Steven Wanderer, Esq.
Attorney for Plaintiff
CAROLINA NAVARRO
RIGGIO MORDAUNT & KELLY
By: _________________________
Michael R. Mordaunt, Esq.
Attorneys for Defendant
TARGET CORPORATION
ORDER
IT IS HEREBY ORDERED pursuant to the stipulation of the parties to this matter that the court's Scheduling Order relative to this matter is modified as follows: Mutual disclosure of expert witnesses and exchange of expert reports shall take place on or before March 20, 2012, and rebuttal expert disclosure authorized under Rule 26 shall take place on or before April 20, 2012. In addition, the discovery completion date shall is May 12, 2012.
_________________________
GARLAND E. BURRELL, JR.
United States District Judge