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STIPULATION AND ORDER TO EXTEND DATES PERTAINING TO EXPERT WITNESS 

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BOWMAN AND BROOKE LLP 

Mike H. Madokoro (SBN: 146970) 

Gregory P. Gilmer (SBN: 212067) 

879 West 190th Street, Suite 700 

Gardena, California 90248 

Telephone: (310) 768-3068 

Facsimile: (310) 719-1019 

Attorneys for Defendant 

ECOLAB INC. 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

JOYCE SHARON FREDRICKSON 

and JERRY FREDRICKSON, 

 Plaintiffs, 

v. 

HOLIDAY RETIREMENT CORP.; 

HILLTOP ESTATES; ECOLAB 

INC.; AND DOES 1 THROUGH 25, 

Inclusive, 

 Defendants. 

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Civil Case No.: CIV.S-04-01061 WBS 

CMK 

(Removed from Shasta County Superior 

Court, Case No. 151501) 

STIPULATION AND ORDER TO 

EXTEND DATES PERTAINING TO 

EXPERT WITNESS DISCLOSURE AND 

PRE-TRIAL STATEMENTS 

Action Filed: April 22, 2004 

Discovery Cut-Off: May 13, 2005 

Motion Cut-Off: July 1, 2005 

Trial Date: October 25, 2005 

WHEREAS the Status (Pre-Trial) Order issued by this Court set 

June 27, 2005, as the last day for parties to disclose their experts and 

produce expert reports in accordance with Federal Rule of Civil Procedure 

26(a)(2); 

WHEREAS the Status (Pre-Trial) Order issued by this Court set 

August 1, 2005, as the last day for the parties to serve their supplemental 

expert disclosures and produce supplemental expert reports in accordance 

with Federal Rule of Civil Procedure 26(a)(2); 

/ / / 

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WHEREAS the Status (Pre-Trial) Order issued by this Court set 

August 10, 2005, as the last day for plaintiffs' counsel to mail or 

electronically serve a pre-trial statement pursuant to Local Rule 16.281(b); 

WHEREAS the parties have agreed to participate in a mediation 

before the Honorable Noel Watkins, Ret. on July 22, 2005 at 9:30 a.m. at 

420 Pine Street, Red Bluff, California 96080; 

IT IS HEREBY STIPULATED AND AGREED by and between all 

parties, through their respective attorneys of record, that the last day for 

the parties to disclose their experts and produce expert reports in 

accordance with Federal Rule of Civil Procedure 26(a)(2) will be July 29, 

2005; 

IT IS FURTHER STIPULATED by and between all parties, through 

their respective attorneys of record, that the last day for the parties to serve 

their supplemental disclosures and produce supplemental expert reports 

will be August 12, 2005; and, 

IT IS FURTHER STIPULATED by and between all parties, through 

their respective attorneys of record, that the last day for plaintiffs' counsel 

to mail or electronically serve a pre-trial statement pursuant to Local Rule 

16-281(b) will be August 17, 2005; and, 

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IT IS FURTHER STIPULATED that this Stipulation may be signed in 

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counterparts and that facsimile signatures will be accepted. 

IT IS SO STIPULATED. 

DATED: June __, 2005 LAW OFFICES OF JAMES A. WYATT 

 By: 

James A. Wyatt 

Attorneys for Plaintiffs JOYCE 

SHARON FREDRICKSON and 

JERRY FREDRICKSON 

DATED: June __, 2005 NISSON & PINCIN 

 By: 

Timothy J. Nisson 

Attorneys for Defendant HILLTOP 

RETIREMENT RESIDENCE II 

LIMITED PARTNERSHIP 

DATED: June __, 2005 BOWMAN AND BROOKE LLP 

 By: 

Mike H. Madokoro 

Gregory P. Gilmer 

Attorneys for Defendant 

ECOLAB INC. 

ORDER

IT IS SO ORDERED. 

DATED: June 15, 2005 

PROOF OF SERVICE

1013A (3) CCP Revised 5/1/88 

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STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State of California. I am over 

the age of 18 years and not a party to the within action; my business 

address is 879 West 190th Street, Gardena, California 90248. 

On June 14, 2005, I served the foregoing document(s) described as 

STIPULATION AND ORDER TO EXTEND DATES PERTAINING TO 

EXPERT WITNESS DISCLOSURE AND PRE-TRIAL STATEMENTS to all 

interested parties [X] by placing a true copy thereof enclosed in (a) sealed 

envelope(s), addressed as follows: 

SEE ATTACHED SERVICE LIST 

[X] BY U.S. MAIL: [X] As follows: I am "readily familiar" with the firm's 

practice of collection and processing correspondence for mailing. Under 

that practice it would be deposited with the U.S. postal service on that same 

day, during the ordinary course of business, with postage thereon fully 

prepaid at Gardena, California. I am aware that on motion of the party 

served, service is presumed invalid if postal cancellation date or postage 

meter date is more than one day after date of deposit for mailing in affidavit. 

[ ] BY PERSONAL SERVICE: I caused to be delivered such envelope 

by hand to the addressee. 

[ ] BY FACSIMILE: The document(s) were transmitted by facsimile 

transmission to each of the parties at the facsimile number(s) listed on the 

attached service/mailing list and the transmission(s) reported as complete 

and without error. The facsimile machine I used complied with the California 

Rules of Court, Rule 2003 and no error was reported by the machine. 

Pursuant to California Rules of Court, Rule 1006(d), I caused the facsimile 

machine to print a transmission record of the transmission. 

Executed on June 14, 2005, at Gardena, California. 

[X] (FEDERAL) I declare that I am employed in the office of a member of 

the bar of this court at whose direction the service was made. 

 ______________________________ 

Vivian Gomez 

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Joyce Sharon Fredrickson, et al. v. Holiday Retirement Corp., et al. 

United States District Court, Case No. CIVS-041061 WBS GGH 

(Removed from Shasta County Superior Court, Case No. 151501) 

Service List

James A. Wyatt, Esq. 

LAW OFFICES OF JAMES A. 

WYATT 

2130 Eureka Way 

Post Office Box 992338 

Redding, CA 96099-2338 

Telephone: (530) 244-6060 

Facsimile: (530) 244-6069 

Attorneys for Plaintiffs 

JOYCE SHARON FREDRICKSON and 

JERRY FREDRICKSON 

(ALSO SENT ELECTRONICALLY) 

Timothy J. Nisson, Esq. 

NISSON & PINCIN 

Post Office Box 991966 

Redding, California 96099-1966 

Telephone: (530) 246-4201 

Facsimile: (530) 246-1426 

Attorneys for Defendant 

HILLTOP RETIREMENT RESIDENCE II 

LIMITED PARTNERSHIP 

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