Ames v. Dorel Home Furnishings, Inc.,et al

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475-1001 	1
CASE NO. 2:25-CV-02407-DJC-DMC
Andrew N. Kohn, Esq., SBN 166385
Emily A. Kirvin, Esq., SBN 357005
PETTIT K OHN I NGRASSIA LUTZ & DOLIN PC
11622 El Camino Real, Suite 300
San Diego, CA 92130
Telephone: (858) 755-8500
Facsimile: (858) 755-8504
Email: akohn@pettitkohn.com
ekirvin@pettitkohn.com
Elise L. Bonine, Esq., SBN 34987
Rachel A. Remke, Esq., admitted pro hac vice
ARENTFOX SCHIFF LLP
44 Montgomery Street, 38th Floor
San Francisco, California 94104
Telephone: 	(415) 757-5500
Facsimile: 	(415) 757-5501
Email: elise.bonine@afslaw.com
rachel.remke@afslaw.com
Attorneys for Defendant
DOREL HOME FURNISHINGS, INC.
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
DEBRA AMES,
Plaintiff,
v.
DOREL HOME FURNISHINGS, INC.,
COSTCO WHOLESALE CORPORATION,
and DOES 1 through 50, Inclusive,
Defendants.
CASE NO.: 2:25-cv-02407-DJC-DMC
JOINT STIPULATION TO EXTEND
FACT DISCOVERY DEADLINE AND
EXPERT DISCLOSURE DEADLINE;
ORDER
Courtroom: 	7
District Judge: 	Daniel J. Calabretta
Magistrate Judge: 	Ila C. Deiss
Complaint Filed: 	August 22, 2025
Trial Date: 	Not Set
Defendant DOREL HOME FURNISHINGS, INC. (“Dorel”), Defendant COSTCO
WHOLESALE CORPORATION (“Costco”) and Plaintiff DEBRA AMES (“Plaintiff”)
(collectively, “the Parties”), by and through their respective counsel undersigned, hereby agree
and stipulate as follows:
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Case 2:25-cv-02407-DJC-ICD Document 26 Filed 10/13/26 Page 1 of 5

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475-1001 	2
CASE NO. 2:25-CV-02407-DJC-DMC
WHEREAS, on October 22, 2025, this Court and the Honorable Daniel J. Calabretta
issued an Order [Doc 13] setting the trial date on December 6, 2027, the Final Status Conference
on September 30, 2027, the last day to hear motions on June 10, 2027, and requiring the Parties to
complete all fact discovery no later than November 20, 2026 and the expert disclosure deadline
no later than December 18, 2026;
WHEREAS, the Parties have diligently pursued discovery to date, including exchanging
written discovery and taking Plaintiff’s deposition, and are continuing to gather Plaintiff’s
medical records and information regarding her treatment, but the timing and scope of further
treatment remain uncertain due to Plaintiff’s ongoing workers’ compensation case;
WHEREAS, the Parties require additional time to complete fact discovery, as Plaintiff’s
course of treatment is ongoing. Remaining fact discovery includes the depositions of Plaintiff’s
treating providers; the depositions of Defendants Dorel and Costco under Federal Rule of Civil
Procedure 30(b)(6); updated written discovery and records subpoenas regarding Plaintiff’s current
and future treatment; and any examination of Plaintiff under Federal Rule of Civil Procedure 35.
The Parties also require additional time to schedule and complete the Rule 30(b)(6) depositions,
including coordinating deponent availability and continuing to meet and confer regarding the
scope of the deposition topics;
WHEREAS, the Parties require additional time to disclose expert witnesses because
Plaintiff may undergo further treatment and more time is needed to assess the status of her current
condition. Requiring expert disclosures by the current deadline would force parties to disclose
and experts to opine potentially prematurely, likely leading to supplemental or amended reports,
duplicative expert discovery, and possible motion practice;
WHEREAS, a clearer understanding of Plaintiff’s treatment course and condition may
also allow the Parties to further develop their evaluations of the case and consider whether it can
be resolved without further litigation expense, including the cost of expert retention and expert
discovery;
WHEREAS, to allow the Parties to complete the foregoing discovery and to disclose
initial experts and produce reports in accordance with Federal Rule of Civil Procedure 26(a)(2),
Case 2:25-cv-02407-DJC-ICD Document 26 Filed 10/13/26 Page 2 of 5

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475-1001 	3
CASE NO. 2:25-CV-02407-DJC-DMC
the Parties respectfully request that the Court modify the Scheduling Order as set forth below, or
as the Court deems appropriate.
THE PARTIES HEREBY STIPULATE AS FOLLOWS:
1. 	The Scheduling Order [Doc. 13] is MODIFIED as follows:
o 	Fact discovery shall be completed by February 1, 2027.
o 	The Parties shall disclose initial experts and serve reports in accordance with
Federal Rule of Civil Procedure 26(a)(2) by February 22, 2027.
o 	Rebuttal expert disclosures and reports shall be served by March 15, 2027.
o 	Expert discovery shall be completed by April 15, 2027.
2. 	All other provisions of the Scheduling Order remain in effect.
3. 	No prior requests for extension of the fact discovery or expert disclosure deadlines have
been made.
The parties respectfully request that the Court enter the [Proposed] Order below pursuant
to the terms of this Stipulation.
IT IS SO STIPULATED.
PETTIT K OHN I NGRASSIA LUTZ & DOLIN PC
Dated: October 2, 2026 	By: 	/s/ Andrew N. Kohn, Esq.
Andrew N. Kohn, Esq.
Emily A. Kirvin, Esq.,
Attorneys for Defendant
DOREL HOME FURNISHINGS, INC.
akohn@pettitkon.com
ekirvin@pettitkohn.com
ARENTFOX SCHIFF LLP
Dated: October 1, 2026 	By: 	/s/ Rachel A. Remke (authorized 10/01/26)
Elise L. Bonine, Esq.
Rachel A. Remke, Esq.
Attorneys for Defendant
DOREL HOME FURNISHINGS, INC.
elise.bonine@afslaw.com
rachel.remke@afslaw.com
Case 2:25-cv-02407-DJC-ICD Document 26 Filed 10/13/26 Page 3 of 5

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475-1001 	4
CASE NO. 2:25-CV-02407-DJC-DMC
MAIRE, POWELL & WERNER
Dated: September 30, 2026 	By: 	/s/ Alexis R. Palma (authorized 9/30/26)
John R. Powell, Esq.
Alexis R. Palma, Esq.
Attorneys for Defendant
COSTCO WHOLESALE
CORPORATION
jpowell@maire-law.com
apalma@maire-law.com
HASLERUD LAW OFFICE
Dated: October 1, 2026 	By: 	/s/ Timothy J. Nisson (authorized 10/01/26
Gary E. Haslerud, Esq.
Timothy J. Nisson, Esq.
Attorneys for Plaintiff
DEBRA AMES
ghaslerud@haslerudlaw.com
tnisson@haslerudlaw.com
ORDER
On or about October 2, 2026, Defendant DOREL HOME FURNISHINGS, INC.
and (“Defendant”) and Plaintiff DEBRA AMES (“Plaintiff”) (collectively, “the Parties”), by and
through their respective counsel, jointly moved this Court for an order to extend the previously
ordered fact discovery deadline until February 18, 2027, and the previously ordered expert
disclosure deadline to March 18, 2027.
Having considered the Parties’ Joint Stipulation, and good cause appearing under Federal
Rule of Civil Procedure 16(b)(4), the Court ORDERS as follows:
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Case 2:25-cv-02407-DJC-ICD Document 26 Filed 10/13/26 Page 4 of 5

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475-1001 	5
CASE NO. 2:25-CV-02407-DJC-DMC
1. 	The Parties’ stipulation is APPROVED.
2. 	The Scheduling Order [DOC 13] is MODIFIED as follows:
o 	Fact discovery shall be completed by February 1, 2027.
o 	The Parties shall disclose initial experts and serve reports in accordance with
Federal Rule of Civil Procedure 26(a)(2) by February 22, 2027.
o 	Rebuttal expert disclosures and reports shall be served by March 15, 2027.
o 	Expert discovery shall be completed by April 15, 2027.
3. 	All other provisions of the Scheduling Order remain in effect.
IT IS SO ORDERED.
Dated: October 9, 2026 	/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE
Case 2:25-cv-02407-DJC-ICD Document 26 Filed 10/13/26 Page 5 of 5