Free Motion for Miscellaneous Relief - District Court of California - California

Case 3:07-cv-02177-JM-JMA

Document 17

Filed 08/26/2008

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KAREN P. HEWITT United States Attorney THOMAS B. REEVE, JR. Assistant United States Attorney California State Bar No. 069310 United States Attorney's Office Room 6293, at 880 Front Street San Diego, California 92101-8893 Tel.: (619) 557. 7159 Attorneys for Defendant, The United States of America

LAW OFFICE OF KATHRYN P. COONEY KATHRYN P. COONEY Attorney at Law California State Bar No. 073322 440 Escondido Way Vista, California 92084 Tel.: (760) 941. 2703 Attorney for the Plaintiff Gary Wheelock UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

GARY WHEELOCK,

) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA ) ) Defendant. ) _________________________________ )

Civil No.

07cv 2177 - JM (JMA)

JOINT MOTION TO RE-SET THE PRE-TRIAL SCHEDULE Hon. Jan M. Adler

The parties have meet and conferred pursuant to the Court's order of August 7, 2008. The parties have considered the unexpected issues and complexity, as well as the other practical and legal aspects of the case and they jointly propose the following new schedule for this case. Event Plaintiff Designates Experts Current Dates August 22, 2008 Proposed New Dates October 3, 2008

Joint Motion Regarding Schedule

07 cv 2177

Case 3:07-cv-02177-JM-JMA

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Filed 08/26/2008

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Event Defendant Designates Experts Supplemental Expert Designations Voluntary Settlement Conference Plaintiff's Expert Reports are due Defendant's Expert Reports are due Last Day to Supplement Expert Reports Briefs for Mandatory Settlement Conference Mandatory Settlement Conference All Factual and Expert Discovery Completed Deadline for Motions to be Filed Memorandum of Contentions of Fact and Law, to be filed (if required) Final Pre-trial Disclosures, Rule 26(a)(3) Objections to Pre-trial Disclosures Comply with L. R. 16.1.f.4: Plaintiff tenders proposed Pre-trial Conf. Order; Exchange Exhibits; craft stipulations, etc., not later than

Current Dates August 22, 2008 September 5, 2008 Not scheduled September 19, 2008 October 17, 2008 November 14, 2008 May 6, 2009 May 13, 2009 January 23, 2009 February 20, 2009 Waived

Proposed New Dates October 3, 2008 October 24, 2008 On or after November 24, 2008 January 16, 2009 February 13, 2009 March 13, 2009 On or after June 8, 2009 On or after June 15, 2009 May 8, 2009 May 25, 2009 Waived

June 5, 2009 June 19, 2009 June 12, 2009

On or after July 24, 2009 On or after August 7, 2009 On or after August 14, 2009

Joint Motion Regarding Schedule

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Case 3:07-cv-02177-JM-JMA

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Filed 08/26/2008

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Event Parties lodge Proposed Pre-trial Conference Order with Court Pre-trial Conference before District Judge Trial

Current Dates June 19, 2009 June 26, 2009 July 27, 2009

Proposed New Dates On or after August 17, 2009 On or after August 24, 2009 On or after September 21, 2009

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The Court is asked to approve the proposed schedule as set out above. A draft proposed order will be concurrently sent to Magistrate Judge Adler's chambers.

Respectfully submitted,

KAREN P. HEWITT United States Attorney /s/ Thomas B. Reeve, Jr. THOMAS B. REEVE, JR. Assistant U.S. Attorney Attorneys For Defendant

Law Office of Kathryn P. Cooney /s/ Kathryn P. Cooney _________________________ KATHRYN P. COONEY Attorney for the Plaintiff Gary Wheelock

Joint Motion Regarding Schedule

07 cv 2177