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Mitchell 

Silberberg & 

Knupp LLP 

0956853.1 

JEFFREY D. GOLDMAN (State Bar No. 155589) 

NICOLE L. HARRIS (State Bar No. 204744) 

MITCHELL SILBERBERG & KNUPP LLP 

11377 West Olympic Boulevard 

Los Angeles, CA 90064-1683 

Telephone: (310) 312-2000 

Facsimile: (310) 312-3100 

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

UMG RECORDINGS, INC., a Delaware 

corporation; UNIVISION MUSIC LLC, 

a Delaware limited liability company; 

DISA LLC, a Delaware limited liability 

company, FONOVISA, a California 

corporation, 

 Plaintiffs, 

v. 

DISCO AZTECA DISTRIBUTORS, 

INC., and DOES 1-10, inclusive, 

 Defendants. 

Case No. CIV S-04-2611 (FCD) 

(DAD) 

Hon. Frank C. Damrell, Jr. 

STIPULATION TO CONTINUE 

EXPERT WITNESS DISCLOSURE 

DEADLINE 

ORDER 

“AS MODIFIED” 

DISCO AZTECA DISTRIBUTORS, 

INC., a California Corporation, 

 Cross-Complainant, 

v. 

UNIVISION MUSIC, LLC, a Delaware 

Limited Liability Company, DISA LLC, 

a Delaware Limited Liability Company 

and ROES 1 through 100, inclusive, 

 Cross-Defendants. 

Case 2:04-cv-02611-FCD-DAD Document 24 Filed 04/06/06 Page 1 of 4
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Plaintiffs and cross-defendants UMG Recordings, Inc., Univision Music 

LLC, Disa LLC, and Fonovisa, Inc. (“Plaintiffs”) and defendant and crosscomplainant Disco Azteca Distributors, Inc. (“Disco Azteca”), by and through their 

respective counsel of record, hereby stipulate as follows: 

1. Pursuant to the Court’s Pre-trial Scheduling Order dated June 30, 

2005 (“June 30 Order”), the deadline to disclose expert witnesses expired on 

March 3, 2006. 

2. In order for Plaintiffs to properly evaluate whether an expert witness 

was necessary to support their claims against Disco Azteca, Plaintiffs needed to 

take the deposition of Disco Azteca’s corporate designee on the various legal and 

factual issues raised in this action. 

3. Plaintiffs initially noticed the deposition of Disco Azteca’s corporate 

designee, pursuant to Federal Rule of Civil Procedure 30(b)(6), for February 22, 

2006. 

4. This date was not convenient for either Disco Azteca’s corporate 

designee, Jose Luis Sanchez, or Disco Azteca’s counsel. Accordingly, at the 

request of Disco Azteca’s counsel, the deposition was rescheduled to a mutually 

convenient date, March 21, 2006. 

5. Just a day before the scheduled deposition, on March 20, 2006, Disco 

Azteca’s counsel contacted Plaintiffs’ counsel an informed counsel that Mr. 

Sanchez had fallen ill, and requested that the deposition be rescheduled. Mr. 

Sanchez’s deposition was rescheduled for and completed on March 28, 2006. 

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6. Because of the delay in taking Mr. Sanchez’s deposition, the parties 

have agreed and request to extend the expert deadline disclosure to April 24, 2006, 

and the deadline to disclose rebuttal experts to May 1, 2006. The parties also have 

agreed and request that the depositions of any disclosed experts shall be completed 

by June 2, 2006. 

7. This is the first request for an extension of pre-trial deadlines 

submitted by the parties, and the proposed deadlines do not conflict the remaining 

pre-trial deadlines contained in the Court’s June 30 Order. 

8. Based on the foregoing, the parties hereby stipulate and request the 

following continuance: 

A. The deadline to disclose expert witnesses is continued to 

April 24, 2006. 

B. The deadline to disclose rebuttal witnesses is continued to 

May 1, 2006. 

C. All expert discovery shall be completed by June 2, 2006. 

D. All other pre-trial deadlines contained in the June 30 Order 

remain unchanged. 

Dated: April _, 2006 JEFFREY D. GOLDMAN 

NICOLE L. HARRIS 

MITCHELL SILBERBERG & KNUPP LLP 

By: ____/s/ Nicole L. Harris_______________ 

Nicole L. Harris 

Attorneys for Plaintiffs and Cross-Defendants 

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Dated: April __, 2006 DAVID S. WHITE 

FAINSBERT MASE & SYNDER LLP 

By: _/s/ David S. White________________ 

David S. White 

Attorneys for Defendants and Cross-Claimants 

ORDER 

Good cause appearing therefore, the pre-trial deadlines pertaining to the 

disclosure of expert witnesses contained in the Court’s Pre-trial Scheduling Order 

dated June 30, 2006, are hereby continued as follows: 

A. The deadline to disclose expert witnesses is continued to 

April 24, 2006. 

B. The deadline to disclose rebuttal witnesses is continued to 

May 1, 2006. 

C. All expert discovery shall be completed by June 2, 2006. 

In light of this extension and to avoid conflicts with the court’s calendar the 

additional following dates are extended: 

Dispositive motions shall be heard no later than August 4, 2006; 

The final pretrial conference is set for October 6, 2006 at 2:30 p.m.; and 

The jury trial is set for December 5, 2006 at 9:00 a.m. 

IT IS SO ORDERED. 

Dated: April 6, 2006 /s/ Frank C. Damrell Jr. 

 Hon. Frank C. Damrell, Jr. 

 United States District Judge 

Case 2:04-cv-02611-FCD-DAD Document 24 Filed 04/06/06 Page 4 of 4