AtPac, Inc v. Aptitude Solutions, Inc., et al
Filing
181
STIPULATION and ORDER signed by Judge William B. Shubb on 6/9/2011 ORDERING that the Federal Rule of Civil Procedure 26(a)(2) deadline is extended to 8/8/2011 and rebuttal reports, if any, are now due 8/29/2011. In light of the foregoing order, no status conference on 6/13/2011 is necessary. (Zignago, K.)
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PILLSBURY WINTHROP SHAW PITTMAN LLP
JOHN S. POULOS #154689
MEREDITH E. NIKKEL #254818
2600 Capitol Avenue, Suite 300
Sacramento, CA 95816-5930
Telephone: (916) 329-4700
Facsimile: (916) 441-3583
Attorneys for Defendants
APTITUDE SOLUTIONS, INC., COUNTY
OF NEVADA and GREGORY DIAZ
DOWNEY BRAND LLP
WILLIAM R. WARNE #141280
MICHAEL J. THOMAS #172326
MICHAEL A. SCHAPS #247423
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Telephone: (916) 444-1000
Facsimile: (916) 444-2100
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Attorneys for Plaintiff
ATPAC, INC., a California Corporation
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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ATPAC, INC.,
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Plaintiff,
vs.
APTITUDE SOLUTIONS, INC., et al.,
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Defendants.
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No. 2:10-CV-00294-WBS-JFM
STIPULATION AND [PROPOSED]
ORDER REQUESTING STATUS
CONFERENCE SOLELY TO MODIFY
EXPERT DISCLOSURE DEADLINES
Date:
Time:
Room:
Judge:
June 13, 2011
2:00 p.m.
5, 14th Floor
Hon. William B. Shubb
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This Stipulation for an order requesting status conference solely to modify expert
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disclosure deadlines (“Stipulation”) is entered into by and between Defendants APTITUDE
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SOLUTIONS, INC., COUNTY OF NEVADA and GREGORY DIAZ (collectively,
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“Defendants”), on the one hand, and Plaintiff ATPAC, INC.’s (“AtPac”), on the other hand
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703048125v1
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STIPULATION AND [PROPOSED] ORDER
REQUESTING STATUS CONFERENCE SOLELY TO
MODIFY EXPERT DISCLOSURE DEADLINES
No. 2:10-CV-00294-WBS-JFM
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solely for the purpose of extending the expert disclosure deadlines. The parties are
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sometimes individually referred to herein as “Party” and collectively referred to as “the
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Parties.”
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WHEREAS, on May 2 and May 5, 2011, Pillsbury Winthrop Shaw Pittman LLP
substituted in as counsel for Defendants; and
WHEREAS, the Parties have agreed to mediate this case on June 21, 2011 before
the Honorable Read Ambler at JAMS; and
WHEREAS, Defendants believe that expert discovery cannot be completed by the
current July 1, 2011 deadline and request that the Federal Rule of Civil Procedure 26(a)(2)
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initial report deadline be extended until August 8, 2011 and the date for Rule 26(a)(2)
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rebuttal reports, if any, be extended to August 29, 2011; and
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WHEREAS, Plaintiff does not oppose Defendants’ request:
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NOW THEREFORE, the Parties agree that a status conference be held on June 13,
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2011 at 2:00 p.m. solely for the purpose of extending the expert discovery deadlines as set
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forth herein. If the Court is able to enter this order amending the scheduling order without
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the need for an appearance, the parties request that the court please do so and advise the
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parties that no appearance is necessary.
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By signing below, counsel for each Party hereby agrees to be bound by the terms of
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this Stipulation and acknowledges that he/she is authorized in his/her representative capacity
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to bind his/her respective client(s) to the terms of this Stipulation.
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Dated: June 8, 2011.
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PILLSBURY WINTHROP SHAW PITTMAN LLP
JOHN S. POULOS
MEREDITH E. NIKKEL
2600 Capitol Avenue, Suite 300
Sacramento, CA 95816-5930
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By
/s/ John S. Poulos
John S. Poulos
Attorneys for Defendants
APTITUDE SOLUTIONS, INC., COUNTY OF
NEVADA and GREGORY DIAZ
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703048125v1
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STIPULATION AND [PROPOSED] ORDER
REQUESTING STATUS CONFERENCE SOLELY TO
MODIFY EXPERT DISCLOSURE DEADLINES
No. 2:10-CV-00294-WBS-JFM
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Dated: June 8, 2011.
DOWNEY BRAND LLP
WILLIAM R. WARNE
MICHAEL J. THOMAS
MICHAEL A. SCHAPS
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
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By
/s/ Michael J. Thomas
Michael J. Thomas
Attorneys for Plaintiff
ATPAC, INC., a California Corporation
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STIPULATION AND [PROPOSED] ORDER
REQUESTING STATUS CONFERENCE SOLELY TO
MODIFY EXPERT DISCLOSURE DEADLINES
No. 2:10-CV-00294-WBS-JFM
ORDER
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The Parties jointly requested a status conference, and Defendants requested that the
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expert discovery deadline of July 1, 2011 be extended to August 8, 2011 for initial reports
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pursuant to Federal Rule of Civil Procedure 26(a)(2) and that the deadline for rebuttal
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reports be extended to August 29, 2011. Plaintiff does not oppose this request.
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IT IS HEREBY ORDERED that:
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1.
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The Federal Rule of Civil Procedure 26(a)(2) deadline is extended to
August 8, 2011; and
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2.
Rebuttal reports, if any, are now due August 29, 2011.
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3.
In light of the foregoing order, no status conference on June 13, 2011 is
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necessary.
Dated: June 9, 2011
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703048125v1
-4-
STIPULATION AND [PROPOSED] ORDER
REQUESTING STATUS CONFERENCE SOLELY TO
MODIFY EXPERT DISCLOSURE DEADLINES
No. 2:10-CV-00294-WBS-JFM
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