Robert E. Renzel Trust et al v. Ventura et al

Northern District of California, cand-4:2015-cv-01648

ORDER by Judge Haywood S. Gilliam, Jr. Granting {{221}} Stipulation re Docket No. {{219}} : Rebuttal Reports due by 8/6/2018 and Close of Expert Discovery due by 9/10/2018.

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1 Jeffery L. Caufield (SBN 166524) jeff@caufieldjames.com 2 Santino M. Tropea (SBN 249215) santino@caufieldjames.com 3 CAUFIELD & JAMES, LLP 2851 Camino Del Rio South, Suite 410 4 San Diego, California 92108 Telephone: 619-325-0441 5 Facsimile: 619-325-0231 6 Attorneys for Defendants, Counter- Claimants, and Cross-Claimants, 7 Alfredo Torres and Carmen Torres 8 UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 11 ESTATE OF ROBERT RENZEL, Case No.: 4:15-cv-01648-HSG 12 DECEASED, by and through his STIPULATION AND ORDER successors in interest, Susan Carter REGARDING CONTINUANCE OF 13 and Ann Renzel Sebastian, et al. REBUTTAL EXPERT EXCHANGE AND EXPERT DISCOVERY CUTOFF 14 Plaintiffs, Current Rebuttal Deadline: 7/6/18 15 Current Expert Discovery Cutoff: 8/24/18 16 v. Proposed Rebuttal Deadline: 8/6/18 Proposed Expert Discovery Cutoff: 9/10/18 17 ESTATE OF LUPE VENTURA, Courtroom: 2, 4th Floor 18 DECEASED, an individual and dba Judge: Hon. Haywood S. Gilliam, Jr. Ritz Cleaners, et al. Action Filed: April 10, 2015 19 Trial Date: December 3, 2018 Defendants. 20 21 AND RELATED COUNTERCLAIMS AND CROSS- 22 CLAIMS. 23 24 25 26 27 28 STIPULATION AND ORDER REGARDING CONTINUANCE OF EXPERT DEADLINES 1 WHEREAS, pursuant to the Court's April 19, 2018 Scheduling Order [Doc. 2 No. 219], the Court set a trial date and certain pretrial deadlines pertaining to expert 3 disclosures, including an expert exchange deadline of June 15, 2018 and rebuttal 4 expert exchange deadline of July 6, 2018 (see chart below). The Court's order 5 indicated that these dates may be altered by order of the Court and upon a showing 6 of good cause. Good cause exists for a thirty (30) day continuance of the rebuttal 7 expert exchange deadline and corresponding expert discovery cutoff. 8 WHEREAS, on June 15, 2018, plaintiffs and counter-defendants Estate of 9 Robert Renzel, Deceased; Robert E. Renzel Trust, by and through its trustees, 10 Susan Carter and Ann Renzel Sebastian; Susan Carter; and Ann Renzel Sebastian 11 (collectively, "Renzel") and defendants and counter-claimants Carmen and Alfredo 12 Torres ("Torres") (collectively "Parties")1, designated and exchanged their experts' 13 opinions. Renzel designated four (4) experts and Torres designated one (1) expert. 14 WHEREAS, the current rebuttal expert exchange deadline is set for twenty- 15 one (21) days after the opening expert exchange. Due to the opening experts, 16 rebuttal experts, and counsel's schedules, and further complicated by the Fourth of 17 July holiday, the Parties are unable to complete the depositions of all experts 18 disclosed prior to the current rebuttal expert deadline, or with sufficient time to 19 obtain transcripts and allow the Parties' rebuttal experts to review and consider the 20 depositions in connection with their rebuttal. 21 WHEREAS, the Parties further exchanged a substantial number of documents 22 relied upon and considered by each of their experts. The current scheduling 23 deadlines do not allow sufficient time for counsel and the Parties' experts to review 24 those documents in advance of the rebuttal exchange. 25 WHEREAS, in consideration of the foregoing, the Parties hereby stipulate to 26 continue the deadlines to exchange expert rebuttal reports for thirty (30) days and 1 27 A copy of this stipulation was provided to all pro se parties via email on June 19, 2018, requesting their review and agreement by signature. None of the pro se parties 28 disclosed opening experts. No objection to the stipulation was received. 1 STIPULATION AND ORDER REGARDING CONTINUANCE OF EXPERT DEADLINES Case No. 4:15-cv-1648-HSG 1 the expert discovery cutoff for seventeen (17) days, as follows: 2 Event Date Proposed Date 3 Exchange Opening June 15, 2018 Completed 4 Expert Reports 5 Exchange Rebuttal July 6, 2018 August 6, 2018 6 Expert Reports 7 Close of Expert August 24, 2018 September 10, 2018 8 Discovery 9 Pretrial Conference November 13, 2018 Same 10 at 3:00 p.m. 11 Jury Trial December 3, 2018 Same 12 at 8:30 a.m. (10 days) 13 WHEREAS, the proposed continuance will not affect the Court's own 14 schedule, including the pretrial conference date or trial date. 15 IT IS THEREFORE HEREBY STIPULATED between the Parties that: 16 (1) The Exchange of Rebuttal Expert Reports shall be continued to August 6, 17 2018; and 18 (2) The close of expert discovery shall be continued to September 10, 2018. 19 20 Respectfully submitted, 21 DATED: June 20, 2018 CAUFIELD & JAMES, LLP 22 s/ Santino Tropea 23 Jeffery Caufield, Esq. Santino Tropea, Esq. 24 Attorneys for Defendants, Counter- Claimants, and Cross-Claimants, 25 Alfredo Torres and Carmen Torres 26 27 28 2 STIPULATION AND ORDER REGARDING CONTINUANCE OF EXPERT DEADLINES Case No. 4:15-cv-1648-HSG 1 DATED: June 20, 2018 PALADIN LAW GROUP LLP 2 s/ Bret Stone 3 Bret Stone, Esq. Attorneys for Renzel 4 5 6 DATED: June 20, 2018 LEWIS BRISBOIS BISGAARD & SMITH LLP 7 8 s/ Glenn A. Friedman Glenn A. Friedman, Esq. 9 Attorneys for Counter Defendants Ann 10 Renzel Sebastian, Susan Carter and the Estate of Robert Renzel 11 12 DATED: June 20, 2018 13 HYANG BAE WHANG, SEON 14 GEUN WHANG, KYU CHUK WHANG 15 Pro se 16 DATED: June 20, 2018 17 GARY TRAN Pro se 18 19 20 DATED: June 20, 2018 THU HUYNH and NGOC T.B. 21 TRAN 22 23 DATED: June 20, 2018 24 UKTAE HAN and MIJA HAN 25 Pro Se 26 27 28 3 STIPULATION AND ORDER REGARDING CONTINUANCE OF EXPERT DEADLINES Case No. 4:15-cv-1648-HSG 1 2 Good cause appearing, IT IS SO ORDERE ED. 3 4 DATED: Ju une 21, 201 18 United Sttates Distriict Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 STIPU ULATION AN ND ORDER RE EGARDING C CONTINUANC CE OF EXPER RT DEADLINE ES Case No. 44:15-cv-1648-HSG G