Burgoyne v. Kronenberger et al
Filing
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STIPULATION AND ORDER re 80 STIPULATION re 66 Case Management Scheduling Order TO EXTEND THE DEADLINES RE AMENDED PLEADINGS, JOINDER OF PARTIES, DISCOVERY CUT-OFF, EXPERT DISCLOSURES, EXPERT DISCOVERY, DISPOSITIVE MO filed by Henry M. Bu rgoyne, III . Amended Pleadings due by 10/15/2012. Discovery due by 2/11/2013. Joinder of Parties due by 10/15/2012. Dispositive Motions due by 4/8/2013. Final Pretrial Conference set for 7/23/2013 02:00 PM in Courtroom E, 15th Floor, San Fr ancisco. Jury Selection set for 8/12/2013 08:30 AM in Courtroom E, 15th Floor, San Francisco before Magistrate Judge Elizabeth D. Laporte. Jury Trial set for 8/12/2013 through 8/20/2013 08:30 AM in Courtroom E, 15th Floor, San Francisco before Magistrate Judge Elizabeth D. Laporte. Signed by Judge Elizabeth D Laporte on 8/1/2012. (kns, COURT STAFF) (Filed on 8/3/2012)
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Scott D. Gattey (SBN 180875)
Gattey Law Office
939 Laurel Street, Suite D
San Carlos, CA 94070
Telephone: (650) 596-7123
Fax: (866) 371-3491
scott@gatteylaw.com
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Rory C. Quintana (SBN 258747)
The Law Offices of Rory C. Quintana
201 Spear Street, Suite 1100
San Francisco, CA 94105
Telephone: (415) 426-3517
Fax: (415) 426-3518
rcquintana@rcqlegal.com
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Attorneys for Plaintiff Henry M. Burgoyne, III
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ANDERIES & GOMES LLP
Shane K. Anderies (SBN 215415)
Allan J. Gomes (SBN 225810)
S. Christine Young (SBN 253964)
601 Montgomery Street, Suite 888
San Francisco, California 94111
Telephone: (415) 217-8802
Facsimile: (415) 217-8803
E-Mail: sanderies@andgolaw.com
Attorneys for Defendants Karl Kronenberger and
Kronenberger Rosenfeld LLP
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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HENRY M. BURGOYNE, III
Plaintiff,
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CASE NO. 3:11-cv-06376 EDL
STIPULATION TO EXTEND DEADLINES
AND AMENDED ORDER FOR: AMENDED
PLEADINGS, JOINDER OF PARTIES,
DISCOVERY CUT-OFF, EXPERT
DISCLOSURES, EXPERT DISCOVERY,
DISPOSITIVE MOTIONS, PRE-TRIAL
CONFERENCE, AND TRIAL DATE
v.
KARL S. KRONENBERGER, an individual;
KRONENBERGER ROSENFELD LLP, a
California limited liability partnership; and
DOES 1 through 10, inclusive,
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Defendants.
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Case No. 3:11-cv-06376-EDL
STIPULATION TO EXTEND DEADLINES AND
[PROPOSED] ORDER FOR: AMENDED PLEADINGS,
JOINDER OF PARTIES, DISCOVERY CUT-OFF, EXPERT
DISCLOSURES, EXPERT DISCOVERY, AND
DISPOSITIVE MOTIONS
Pursuant to an agreement set forth at the June 19, 2012 mediation, and in an effort to
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continue good faith efforts toward informal resolution, the parties hereby agree to further
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continue the deadlines set forth for Amended Pleadings, Joinder of Parties, Discovery, Motions,
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and Trial as follows: (1) Amended Pleadings Deadline, currently set for July 15, 2012, will be
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extended to October 15, 2012; (2) Joinder of Parties Deadline, currently set for July 15, 2012,
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will be extended to October 15, 2012; (3) the Discovery Deadline, currently set for October 26,
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2012, will be extended to February 11, 2013; (4) Initial Expert Disclosures, currently set for
November 9, 2012, will be extended to February 8, 2013; (5) Rebuttal Expert Disclosures,
currently set for November 30, 2012, will be extended to March 2, 2013; (6) the Expert
Discovery Deadline, currently set for December 21, 2012, will be extended to March 21, 2013;
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(7) Dispositive Motions filing Deadline, currently set for January 22, 2013, will be extended to
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April 18, 2013; (8) the Pre-Trial Conference, currently set for May 7, 2013 at 2:00 p.m., will be
extended to July 22, 2013, at a time to be set by the Court; and (9) the Jury Trial, currently set for
May 28, 2013, will be extended to August 12, 2013.
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The parties respectfully request the Court enter an order that current deadlines listed
above be extended as agreed to by the parties.
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WHEREAS, Plaintiff and Defendants agreed to the above scheduling changes during
mediation on June 19, 2012;
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THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff and Defendants
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through their designated counsel that the above scheduling changes be granted and entered by the
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Court.
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IT IS SO STIPULATED.
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Dated: July 30, 2012
THE LAW OFFICES OF RORY C. QUINTANA
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By:___s/Rory C. Quintana_______________
Rory C. Quintana
Attorney for Plaintiff Henry M. Burgoyne, III
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Case No. 3:11-cv-06376-EDL
STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: AMENDED PLEADINGS, JOINDER OF
PARTIES, DISCOVERY CUT-OFF, EXPERT DISCLOSURES,
EXPERT DISCOVERY, AND DISPOSITIVE MOTIONS
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Dated: July 30, 2012
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ANDERIES & GOMES LLP
By:____________________________________
Shane K. Anderies
Attorney for Defendants Karl M. Kronenberger
and Kronenberger Rosenfeld LLP
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Filer’s Attestation: Pursuant to General Order No. 45 §X(B), I attest under penalty of
perjury that concurrence in the filing of the document has been obtained from its signatory.
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Dated: July 30, 2012
Respectfully submitted,
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By:___s/Rory C. Quintana_______________
Rory C. Quintana
Attorney for Plaintiff Henry M. Burgoyne, III
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Case No. 3:11-cv-06376-EDL
STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: AMENDED PLEADINGS, JOINDER OF
PARTIES, DISCOVERY CUT-OFF, EXPERT DISCLOSURES,
EXPERT DISCOVERY, AND DISPOSITIVE MOTIONS
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1. The proposed deadlines as described above shall be granted. The Pretrial
Conference is set for Tuesday, July 23, 2013, at 2:00 p.m.
IT IS SO ORDERED.
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UNIT
ED
August 1, 2012
Dated:_____________________________
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S DISTRICT
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UNITED STATES MAGISTRATE JUDGE
DERED
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SOFOR ED
IT IS
NORTHERN DISTRICT
CALIFORNIA
DIFI
AS MO
e
. Laport
zabeth D
li
Judge E
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ER
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R NIA
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therefore, orders as follows:
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The Court having considered the stipulation of the parties, and good cause appearing
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D IS T IC T O
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Case No. 3:11-cv-06376-EDL
STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: AMENDED PLEADINGS, JOINDER OF
PARTIES, DISCOVERY CUT-OFF, EXPERT DISCLOSURES,
EXPERT DISCOVERY, AND DISPOSITIVE MOTIONS
CERTIFICATE OF SERVICE
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I, Rory C. Quintana, hereby certify that on July 30, 2012, I authorized and served by
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electronic means on the parties listed below, as follows:
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ANDERIES & GOMES LLP
Shane K. Andereies (SBN 215415)
Allan J. Gomes (SBN 225810)
S. Christine Young (SBN 253964)
601 Montgomery Street, Suite 888
San Francisco, California 94111
Telephone: (415) 217-8802
Facsimile: (415) 217-8803
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I certify under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed on July 30, 2012.
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By:___s/Rory C. Quintana_______________
Rory C. Quintana
Attorney for Plaintiff Henry M. Burgoyne, III
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Case No. 3:11-cv-06376-EDL
STIPULATION TO EXTEND DEADLINES AND [PROPOSED]
ORDER FOR: AMENDED PLEADINGS, JOINDER OF
PARTIES, DISCOVERY CUT-OFF, EXPERT DISCLOSURES,
EXPERT DISCOVERY, AND DISPOSITIVE MOTIONS
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