Opinion
SEYFARTH SHAW LLP, Courtney K. Bohl, Attorneys for Defendant, TARGET CORPORATION.
LAW OFFICE OF DEAN B. GORDON, Dean B. Gordon, Attorney for Plaintiff SANDRA SANCHEZ.
STIPULATION AND ORDER TO CONTINUE DEADLINES
SHEILA K. OBERTO, Magistrate Judge.
Pursuant to Civ. L.R. 144, and subject to approval of the Court, Plaintiff Sandra Sanchez ("Plaintiff") and Defendant Target Corporation ("Target"), by and through their attorneys enter into the following stipulation and respectfully request the Court's acceptance of this stipulation:
WHEREAS, on August 27, 2014 the Court issued a Scheduling Order ("Scheduling Order") in the above referenced action;
WHEREAS, pursuant to the Scheduling Order, the deadline for Non Expert Discovery is April 17, 2015, the deadline for Expert Disclosure is May 1, 2015, the deadline for Supplemental Expert Disclosure is May 15, 2015, and the deadline for Expert Discovery is June 10, 2015;
WHEREAS, pursuant to the Scheduling Order, the deadline to file dispositive motions is June 12, 2015, and the deadline for hearing on dispositive motions is July 15, 2015;
WHEREAS, pursuant to the Scheduling Order, the Settlement Conference is set for April 27, 2015, the Pretrial Conference is set for August 19, 2015, and Trial is set for September 29, 2015;
WHEREAS, the parties have informally engaged in settlement discussions for the last three months, during which time the parties conducted informal discovery to conserve resources while attempting to settle this matter;
WHEREAS, it has taken the parties more time than expected to mutually agree on a mediator and to schedule a mediation date;
WHEREAS, the parties have a mediation set for April 15, 2015 with Buzz Wiesenfeld of Judicate West;
WHEREAS, the parties agree that they would like to avoid the expense of time and resources associated with further discovery in this matter while they engage in settlement discussions and attend mediation. The parties believe that a continuance of the current trial date and all related scheduled dates will promote judicial economy in that the parties will be able to delay incurring further litigation expenses until after the mediation;
WHEREAS, the parties have met and conferred regarding continuing the dates set forth in the Court's August 27th scheduling order;
WHEREAS, Defendant is unavailable in December 2015 and counsel for Plaintiff is unavailable in January and February 2016 due to trials in other cases;
WHEREAS, the parties respectfully request that the Court vacate the current trial date and pretrial deadlines and reschedule all associated dates and deadlines by approximately 160 days at times convenient for the Court and counsel. This additional time will allow the parties to continue engaging in settlement discussions, and complete discovery before the dispositive motion deadline, assuming mediation is unsuccessful;
WHEREAS, the Parties have not requested any prior extension in this matter.
NOW, THEREFORE, the Parties agree and stipulate, subject to the approval of the Court, that:
1. The April 17, 2015 deadline for Non-Expert Discovery be continued to on or after September 24, 2015;
2. The May 1, 2015 deadline for Expert Disclosure be continued to on or after October 8, 2015;
3. The May 15, 2015 deadline for Supplemental Expert Disclosure be continued to on or after October 22, 2015;
4. The June 10, 2015 deadline for Expert Discovery be continued to on or after November 17, 2015;
5. The June 12, 2015 deadline to file dispositive motions be continued to on or after November 19, 2015 and the deadline for hearing on dispositive motions to be continued to February 22, 2016;
6. The April 27, 2015 Settlement Conference be continued to on or after October 5, 2015, and the August 19, 2015 Pretrial Conference be continued to on or after January 26, 2016; and
7. The September 29, 2015 Trial date be continued to on or after March 7, 2016;
IT IS SO STIPULATED
ORDER
Pursuant to the parties' stipulation, the case deadlines are modified as follows:
Event Current Date Modified Date Non-Expert Discovery April 17, 2015 September 24, 2015 Expert Disclosure May 1, 2015 October 8, 2015 Suppl. Expert Disclosure May 15, 2015 October 22, 2015 Expert Discovery June 10, 2015 November 17, 2015 Motion Filing Deadline June 12, 2015 November 18, 2015 Motion Hearing Deadline July 25, 2015 December 16, 2015 Settlement Conference April 27, 2015 October 27, 2015 at 10:30 a.m. in Courtroom 9 Pre-trial Conference August 19, 2015 January 27, 2016 Trial September 29, 2015 March 8, 2016
In light of the parties' requested trial date of March 7, 2016, the parties' requested February 22, 2016, deadline for hearing all motions could not be accommodated. The dates for motion hearings, settlement conference, pre-trial conference, and trial have been adjusted by a few days to comport with the Court's calendar.
IT IS SO ORDERED.