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DIEPENBROCK 

HARRISON

ATTORNEYS AT LAW

EILEEN M. DIEPENBROCK – SBN 119254 

CHRIS A. McCANDLESS - SBN 210085 

DIEPENBROCK HARRISON 

A Professional Corporation 

400 Capitol Mall, Suite 1800 

Sacramento, CA 95814-4413 

Telephone: (916) 492-5000 

Facsimile: (916) 446-4535 

Attorneys for Defendant 

CAVIAR CREATOR, INC., a Nevada corporation

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

DANIEL W. FAERFERS and KATJA 

FAERFERS, 

Plaintiffs, 

v. 

CAVIAR CREATOR, INC., a Nevada 

corporation, individually and as successor 

to n Oregon corporation; CAVIAR 

CREATOR, INC., a Nevada corporation, 

Defendants.

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Case No.: 2:04-cv-2690 MCE PAN 

STIPULATION AND ORDER TO 

CONTINUE DISCOVERY 

COMPLETION DATE 

WHEREAS, pursuant to the Court’s scheduling Order dated September 20, 2005, all 

all discovery, with the exception of expert discovery, shall be completed by January 13, 

2006 in the above-referenced action; 

WHEREAS many of the parties and third-party witnesses reside outside the United 

States, including in Germany; 

WHEREAS, the parties have been diligently proceeding with discovery; 

WHEREAS the depositions of parties and witnesses have taken longer than initially 

expected because of language translation issues; 

WHEREAS the parties hereto have stipulated that the currently scheduled date for 

completion of discovery should be continued to allow additional time for parties, witnesses, 

Case 2:04-cv-02690-TLN-EFB Document 84 Filed 01/06/06 Page 1 of 3
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DIEPENBROCK 

HARRISON

ATTORNEYS AT LAW

and/or counsel to travel to/from Germany as necessary in this case; 

THEREFORE, IT IS HEREBY STIPULATED by and between the parties hereto 

through their respective attorneys of record; Vaughan & Associates, Cris C. Vaughan, for 

Plaintiffs/cross-defendants Daniel W. Faerfers and Katja Faerfers; Boutin, Dentino, et al., 

James P. Kirkley, for defendant/cross-claimant Sinclair Wilson; and Diepenbrock Harrison, 

Eileen M. Diepenbrock for Defendant/counterclaimant/cross-claimant Caviar Creator, Inc., 

that the currently scheduled discovery completion date of January 13, 2006, be continued to 

April 15, 2006. To the extent this extension requires other modifications to the Court’s 

September 20, 2005, Scheduling Order, the parties have no objection thereto. 

SO STIPULATED. 

DATED: December 21, 2005 DIEPENBROCK HARRISON 

 

By: 

__________/s/___________________ 

 Eileen M. Depenbrock 

 Attorneys for Caviar Creator, Inc. 

DATED: December 21, 2005 BOUTIN, DENTINO, ET., AL 

 By: 

_________/s/____________________ 

James P. Kirkley 

 Attorneys for Sinclair Wilson 

DATED: December 20, 2005 VAUGHAN & ASSOCIATES 

 By: 

________s/s___________________ 

 Cris C. Vaughan 

Attorneys for Plaintiffs DANIEL 

FAERFERS and KATJA FAEFERS 

Original Signatures maintained by 

Diepenbrock Harrison 

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DIEPENBROCK 

HARRISON

ATTORNEYS AT LAW

ORDER

PURSUANT TO STIPULATION, the currently scheduled discovery completion date 

of January 13, 2006, is hereby continued to April 15, 2006. 

Other modifications to the Court’s September 20, 2005 Scheduling Order are as 

follows: 

Deadline/Hearing Current Dates (vacated) New Dates 

Jury Trial 10/25/06 at 09:00 a.m. 01/24/07 at 9:00 a.m. 

Final Pretrial Conference 08/28/06 at 02:30 p.m. 12/18/06 at 01:30 p.m. 

Dispositive Motion Hearing 

Deadline 

06/12/06 09/11/06 

Designation of Expert Witnesses 

deadline 

03/13/06 06/15/06 

Discovery completion deadline 01/13/06 04/15/06 

IT IS SO ORDERED. 

DATED: January 6, 2006

__________________________________ 

MORRISON C. ENGLAND, JR 

UNITED STATES DISTRICT JUDGE 

 

Case 2:04-cv-02690-TLN-EFB Document 84 Filed 01/06/06 Page 3 of 3