Fisher v. Target Corporation ( 2019 )

1 Michael R. Mordaunt, Esq., Bar No. 66911 Richard J. Sordello, Jr., Esq., Bar No. 155068 2 RIGGIO MORDAUNT & KELLY A Professional Law Corporation 3 2509 West March Lane, Suite 200 Stockton, CA 95207 4 Telephone: (209) 473-8732 5 Attorneys for Defendant TARGET CORPORATION 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 CATHERINE FISHER AND DONALD Case No. 2:19-cv-00114-TLN-KJN 11 FISHER, STIPULATION FOR EXTENSION OF 12 Plaintiff(s), DEADLINES AND ORDER 13 vs. 14 TARGET CORPORATION; DOE EMPLOYEE 1; AND DOES 1 through 15 50, inclusive, 16 Defendant(s). 17 Plaintiffs CATHERINE FISHER and DONALD FISHER first filed their complaint against 18 defendant TARGET CORPORATION in this matter on November 9, 2018, in the Sacramento 19 County Superior Court. On January 16, 2019, defendant TARGET CORPORATION filed its 20 Notice of Removal and Answer, and thereafter, and on February 15, 2019, plaintiffs filed their 21 motion to remand. The motion was fully briefed by the parties, and on March 15, 2019, the court 22 took the matter under submission. To date, the court has not ruled on said motion. 23 The parties have not completed discovery in this matter and wish to obtain an extension of 24 the discovery deadlines because neither party has completed discovery and both parties will be 25 prejudiced if an extension is not granted. 26 THEREFORE, the parties hereby stipulate and agree that the court’s Scheduling Order 27 relative to this matter shall be modified as follows: 1 2. The parties shall make expert witness disclosures under Fed. R. Civ. P. 26(a)(2) by 2 April 17, 2020. Supplemental disclosure and disclosure of any rebuttal experts under Fed. R. Civ. 3 P. 26(a)(2)(c) shall be made by May 17, 2020. 4 3. All dispositive motions shall be heard no later than August 15, 2020. 5 Dated: August 16, 2019 DEMAS LAW GROUP, P.C. 6 7 By: /s/ John M. Demas, Esq. John N. Demas, Esq. 8 Attorneys for Plaintiff DONALD FISHER 9 Dated: August 16, 2019 ELIOT REINER, A.P.L.C. 10 11 By: /s/ Eliot M. Reiner, Esq. Eliot M. Reiner, Esq. 12 Attorneys for Plaintiff DONALD FISHER 13 Dated: August 16, 2019 RIGGIO MORDAUNT & KELLY 14 15 By: /s/ Richard J. Sordello, Jr. Esq. Richard J. Sordello, Jr. Esq. 16 Attorneys for Defendant TARGET CORPORATION 17 18 19 20 21 22 23 24 25 26 27 1 ORDER 2 Good cause having been shown, 3 IT IS HEREBY ORDERED that the parties to this matter that the court’s Scheduling Order 4 relative to this matter is modified as follows: 5 1. All discovery, except non-expert shall be completed by February 17, 2020. 6 2. The parties shall make expert witness disclosures under Fed. R. Civ. P. 26(a)(2) by 7 April 17, 2020. Supplemental disclosure and disclosure of any rebuttal experts under Fed. R. Civ. 8 P. 26(a)(2)(c) shall be made by May 17, 2020. 3. All dispositive motions shall be heard no later than August 15, 2020. 9 10 11 DATED: August 16, 2019 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27