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DISCOVERY CUT-OFF; [PROPOSED] ORDER; CASE NO. 3:17-cv-00602 JST

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Anne M. Bevington, Esq. (SBN 111320)

Kimberly A. Hancock, Esq. (SBN 205567)

Matthew P. Minser, Esq. (SBN 296344)

SALTZMAN & JOHNSON LAW CORPORATION

44 Montgomery Street, Suite 2110

San Francisco, CA 94104

(415) 882-7900

(415) 882-9287 – Facsimile

abevington@sjlawcorp.com

khancock@sjlawcorp.com

mminser@sjlawcorp.com

Attorneys for Plaintiffs, Automotive Industries 

Pension Trust Fund, et al.

Robert F. Schwartz, No. 227327

Clarissa A. Kang, No. 210660

Jahiz Noel Agard, No. 282988

TRUCKER  HUSS

A Professional Corporation

One Embarcadero Center, 12th Floor

San Francisco, CA 94111

Telephone: (415) 788-3111

Facsimile: (415) 421-2017

E-mail: rschwartz@truckerhuss.com

ckang@truckerhuss.com

jagard@truckerhuss.com

Attorneys for Defendants

Mike Rose’s Auto Body, Inc., et al.

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

(SAN FRANCISCO DIVISION)

AUTOMOTIVE INDUSTRIES PENSION 

TRUST FUND, et al.,

Plaintiffs,

v.

MIKE ROSE’S AUTO BODY INC., a 

California corporation, et al.

Defendants.

 Case No.: Case No. 17-cv-00602 JST 

STIPULATION AND JOINT REQUEST 

TO FURTHER MODIFY SCHEDULING 

ORDER TO EXTEND DISCOVERY CUTOFF DATES; AND

[PROPOSED] ORDER

Complaint Filed: February 6, 2017

IT IS HEREBY STIPULATED by and between the parties to this action, by and through 

their attorneys of record, and the parties jointly request that the Court modify its Scheduling 
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DISCOVERY CUT-OFF; [PROPOSED] ORDER; CASE NO. 3:17-cv-00602 JST

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Order, initially issued June 21, 2017 (Doc. No. 26) and modified on February 14, 2018 (Doc. No. 

36), as follows:

The parties submit that good cause exists for the following reasons. 

1. The Scheduling Order was initially issued on June 21, 2017, and modified pursuant 

to the parties’ joint request on February 14, 2018. The currently requested extensions are for 

discovery cut-off dates only and do not delay the dates for filing dispositive motions, or for the 

pretrial conference and trial. 

2. The parties are actively engaged in settlement negotiations and wish to attempt a 

resolution of this matter before incurring further expense of discovery. 

3. The parties have propounded written discovery and have conferred regarding the 

setting of depositions. The parties have agreed on the following discovery plan, subject to the 

Court’s granting their joint request to modify the schedule:

• April 3, 2018 – Defendant’s Responses to Plaintiffs’ Written Discovery due.

Event Scheduled Date Requested Date Previous Extension

Fact discovery cut-off Mar. 30, 2018 April 30, 2018 1

Expert disclosures Apr. 23, 2018 May 14, 2018 1

Expert rebuttal May 15, 2018 May 28, 2018 1

Expert discovery cutoff June 1, 2018 June 8, 2018 1

Deadline to file dispositive 

motions

Jun. 21, 2018 No change None

Pretrial conference statement 

due

Sept. 25, 2018 No change None

Pretrial conference Oct. 5, 2018

2:00 p.m.

No change None

Trial Oct. 29, 2018

8:30 a.m.

No change None
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DISCOVERY CUT-OFF; [PROPOSED] ORDER; CASE NO. 3:17-cv-00602 JST

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• April 15, 2018 – Plaintiff’s Responses to Defendants’ Written Discovery due.

• Depositions may be conducted at any time pursuant to the Federal Rules of Civil 

Procedure and the Civil Local Rules, or by mutual agreement.

7. The parties respectfully request that the Court approve this stipulation and 

incorporate its terms in an Order.

IT IS SO STIPULATED.

DATED: March 9, 2018

SALTZMAN & JOHNSON LAW CORPORATION

By: /S/_Anne M. Bevington____

 Anne M. Bevington

 Attorneys for Plaintiffs

DATED: March 9, 2018

TRUCKER  HUSS

By: /S/ Robert F. Schwartz

 Robert F. Schwartz

 Attorneys for Defendants

CERTIFICATION RE SIGNATURES

I attest that concurrence in the filing of this document has been obtained from Anne M. 

Bevington.

Dated: March 9, 2018 /s/ Robert F. Schwartz

Robert F. Schwartz

IT IS SO ORDERED.

Dated: ____________, 2018

HON. JON S. TIGAR

United States District Judge

March 12 The Court is unlikely to grant any further requests for continuance.