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Gabriel Hernandez, et al v. Creative Concepts

May 6, 2013

GABRIEL HERNANDEZ, ET AL.,
PLAINTIFFS,
v.
CREATIVE CONCEPTS, ET AL.,
DEFENDANTS.



The opinion of the court was delivered by: Cam Ferenbach United States Magistrate Judge

ORDER

(Stipulation and Request for Revised Discovery Plan and Scheduling Order and Identification of Disputed Scope of Discovery Pursuant to the Court's April 22, 2013, Order #241 (#251) and Motion to Request A Discovery Conference (#253))

Before the court is the parties' Stipulation and Request for Revised Discovery Plan and Scheduling Order and Identification of Disputed Scope of Discovery Pursuant to the Court's April 22, 2013, Order #241. (#251).

Also before the court is NPL Construction Company's (hereinafter "NPL") Motion to Request A Discovery Conference. (#253).

Stipulation and Request for Revised Discovery Plan and Scheduling Order (#251)

A. Stipulated Extended Deposition and Discovery Schedule

The parties state in the stipulation that they agree to extend the following deposition and discovery deadlines:

NPL's Disclosure of Its Rebuttal Economic Damages Expert May 10, 2013 Deposition of Aida Real May 21-22, 2013 Deposition of John Speidel May 23-24, 2013 NPL's Disclosure of Rebuttal Immigration Expert Witness May 24, 2013 Deposition of Ricardo Pringle May 30-31, 2013 Deposition of Chris Brelje June 3, 2013 Depositions of Troy Ware, Andrew Pressimone, June 4-6, 2013 (or a mutually and Guillermo Negron convenient time after May 31, 2013)

Deposition of NPL's Rebuttal Immigration Expert Witness June 7, 2013 Deposition of Michael Kemper June 18-19, 2013 Reopened Deposition of Dan Weaklend June 21, 2013 Reopened Deposition of Cavin Donnell June 28, 2013 Deposition of NPL's Rebuttal Economic Damages Expert To be completed July 9, 10, 11, or 12 (depending upon witness availability) (#251). The parties agree that they will be allowed to subpoena documents from third parties. Id. The parties also agree that:

NPL will transmit to Plaintiffs an unsigned, updated release of records for Plaintiffs Ivan Madrigal and Carlos Navarrete whose prior releases have expired and/or were not considered to be sufficient by the third party from whom records were sought, resulting in the non-disclosure of records by third parties. Plaintiffs will execute the same and transmit the executed releases to NPL within three (3) weeks of the date received by Plaintiffs' counsel. NPL will continue to supplement its discovery responses with any documents it receives in response to such subpoenas duces tecum or Freedom of Information Act requests.

In addition to the agreed upon schedule above, the following deadlines are set by the court for the reasons set forth below:

Discovery Cut-Off August 15, 2013 Dispositive Motions Deadline September 27, 2013 Joint Pretrial Order October 28, 2013. If dispositive motions are filed, the joint pretrial order is due thirty days from the entry of the court's rulings on the motions.

B. Disputed Areas of ...


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