JOINT STIPULATION oc-fs1\HERTERS\31579v01\71233.010500

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GREENBERG TRAURIG, LLP 

GREGORY F. HURLEY (SBN 126791) 

STACEY L. HERTER (SBN 185366) 

650 Town Center Drive, Suite 1700 

Costa Mesa, California 92626 

Telephone: (714) 708-6500 

Facsimile: (714) 708-6501 

Email: herters@gtlaw.com

Attorneys for Defendant 

RALPHS GROCERY COMPANY 

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA 

JAMES SANFORD, 

 Plaintiff, 

vs. 

RALPHS GROCERY COMPANY dba 

RALPHS #983; BILL DEFAZIO, and 

DOES 1 through 10, 

 Defendants. 

CASE NO. 04-2037 LKK KJM 

STIPULATION AND ORDER RE 

CONTINUANCE OF DATES 

Date Filed: September 29, 2004 

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JOINT STIPULATION 

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The parties hereto, by and through undersigned counsel of record, hereby file the 

following joint stipulation regarding the continuance of the expert deadlines in this case. 

JOINT STIPULATION

WHEREAS, this action was filed on September 29, 2004; 

WHEREAS, the deadlines currently set in this case are as follows: 

• the expert designation date is November 11, 2005; 

• the discovery completion date is January 10, 2006; 

• trial is set to begin on September 12, 2006; 

WHEREAS, in or about April 2005, Plaintiff James Sanford noticed a site 

inspection scheduled for October 19, 2005; 

WHEREAS, Plaintiff only recently served the landlord in this action, The 

Cushman Family Trust, on August 23, 2005; 

WHEREAS, The Cushman Family Trust has not yet answered or appeared in this 

case; 

WHEREAS, Ralphs is currently considering The Cushman Family Trust’s tender 

of defense and indemnity and therefore needs additional time to evaluate settlement 

possibilities, or alternatively, to make arrangements for The Cushman Family Trust’s 

counsel to appear at the site inspection in order to avoid duplicative site inspections; 

WHEREAS, the parties have not previously requested a continuance of any of the 

dates in the scheduling order; 

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JOINT STIPULATION 

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THEREFORE, through this Joint Stipulation, Plaintiff and Ralphs respectfully 

request that the Court approve the following new dates in this case: 

• December 12, 2005 as the new date for expert designation; and 

• February 10, 2006 as the new discovery completion date. 

DATED: October ___, 2005 GREENBERG TRAURIG, LLP 

By /signature on original

Stacey L. Herter 

Attorneys for Defendant 

RALPHS GROCERY COMPANY 

DATED: October __, 2005 LAW OFFICES OF LYNN HUBBARD 

By /signature on original

Lynn Hubbard 

Attorneys for Plaintiff 

JAMES SANFORD 

ORDER

IT IS SO ORDERED. 

DATED: October 27, 2005. /s/Lawrence K. Karlton

Lawrence K. Karlton 

Senior Judge 

Case 2:04-cv-02037-LKK -KJM Document 22 Filed 10/27/05 Page 3 of 3