Dairy America, Inc. v. New York Marine and General Insurance Company et al

Filing 141

Joint STIPULATION and ORDER to Continue Expert Disclosusre Deadline Scheduling Conference Dates: 1) Expert Disclosure Deadline is 2/15/2010; 2) Supplemental Expert Disclosure Deadline is 3/15/2010. signed by Judge Sandra M. Snyder on 1/8/2010. (Herman, H)

Charles K. Manock Sherrie M. Flynn 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DAIRYAMERICA, INC., A t t o r n e ys for
F IG G A R D E N F IN A N C IA L C E N T E R

#161633 #240215

B AK E R , M AN O C K & J E N S E N , P C
5260 NORTH PALM AVENUE, FOURTH FLOOR

F RESNO, CALIFORNIA 93704-2209 TE L E P H O N E [phone] TE L E C O P IE R [phone]

Plaintiff DAIRYAMERICA, INC.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

) ) Plaintiff, ) ) v. ) ) NEW YORK MARINE AND GENERAL ) INSURANCE COMPANY; CRUMP ) INSURANCE SERVICES d.b.a. SOUTHERN ) MARINE & AVIATION UNDERWRITERS; ) ARTHUR J. GALLAGHER & CO.; and ) HARTFORD CASUALTY INSURANCE ) COMPANY; and DOES 1 through 75 ) ) Defendants. ) ) )

Case No.: 1:07-cv-00537-LJO-SMS JOINT STIPULATION AND ORDER TO CONTINUE EXPERT DISCLOSURE DEADLINE SCHEDULING CONFERENCE DATES

ACTION FILED: February 16, 2007 TRIAL DATE: August 30, 2010

WHEREAS, on August 20, 2009, the Court entered an amended Scheduling Conference Order (Document No. 113) setting forth the following deadlines, among others, in this matter: Expert Disclosure Deadline: January 15, 2010

Supplemental Expert Disclosure Deadline: February 19, 2010 Expert Discovery Cutoff: Settlement Conference: Dispositive Motion Filing Deadline: April 23, 2010 May 10, 2010 May 19, 2010

J O I N T STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCLOSURE DEADLINES A N D EXPERT DISCOVERY CUTOFF SCHEDULING CONFERENCE DATES

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 /// /// /// ///

Dispositive Motion Hearing Deadline: Pre-Trial Conference Date: Trial Date:

June 25, 2010 July 15, 2010 August 31, 2010

WHEREAS, on August 25, 2009, this Court entered a Minute Order, advancing the date for trial to Monday, August 30, 2010 at 8:30 a.m. in Courtroom 4 before District Judge Lawrence J. O'Neill. WHEREAS, Plaintiff and Defendants wish to continue the Expert Disclosure Deadline and Supplemental Expert Disclosure Deadline to allow further time for preparation of expert reports, but still allowing adequate time for expert discovery; Accordingly, pursuant to the Local Rules of the United States District Court for the Eastern District of California, Rules 6-144 and 83-143, Plaintiff and Defendants, by and through their respective attorneys of record, STIPULATE AND AGREE that: 1. Subject to the Court's approval, the Expert Disclosure Deadline and

Supplemental Expert Disclosure Deadline in this matter are continued as follows: Expert Disclosure Deadline: February 15, 2010

Supplemental Expert Disclosure Deadline: March 15, 2010 All parties that have appeared in this action and are affected by this stipulation, have signed below, indicating their agreement to this stipulation. DATED: January 7, 2010 BAKER MANOCK & JENSEN, PC By: /s/ Sherrie M. Flynn Charles K. Manock Sherrie M. Flynn Attorneys for Plaintiff DAIRYAMERICA, INC.

2
J O I N T STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCLOSURE DEADLINES A N D EXPERT DISCOVERY CUTOFF SCHEDULING CONFERENCE DATES

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

DATED: January 7, 2010

SNYDER LAW, A PROFESSIONAL CORPORATION By: /s/ Ashley Ann Doris Barry Clifford Snyder Ashley Ann Doris Attorneys for Defendant ARTHUR J. GALLAGHER & CO.

DATED: January 6, 2010

CANNON & NELMS By: /s/ Robert W. Nelms Robert W. Nelms Attorneys for Defendant HARTFORD CASUALTY INSURANCE COMPANY

PURSUANT TO THIS STIPULATION, IT IS SO ORDERED.

Dated:

January 8, 2010

/s/ Sandra M. Snyder UNITED STATES MAGISTRATE JUDGE

C:\WINDOWS\Temp\notes101AA1\~3716824.WPD- 11520.0010

3
J O I N T STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCLOSURE DEADLINES A N D EXPERT DISCOVERY CUTOFF SCHEDULING CONFERENCE DATES