The Meat Market, Inc. v. The American Insurance Company

Filing 21

STIPULATION to continue deadlines to disclose experts and to file Dispositive Motions; ORDER Thereon, signed by Magistrate Judge Dennis L. Beck on 6/19/2012. (Designation of Expert Witnesses due by 8/3/2012; Dispositive Motions filed by 8/10/2012; Supplemental Designation of Expert Witnesses due by : 8/17/2012; Dispositive Motions heard by 9/17/2012) (Figueroa, O)

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MARJIE D. BARROWS (SBN 122129)
KATHLEEN M. DeLANEY (SBN 196376)
FORAN GLENNON PALANDECH PONZI & RUDLOFF PC
2000 Powell Street, Suite 900
Emeryville, CA 94608
Telephone: [phone]
Facsimile: [phone]
E-mail:
[e-mail]
E-mail:
[e-mail]
Attorneys for Defendant THE AMERICAN
INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION

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THE MEAT MARKET, INC., dba
STATE CENTER FOODS,

No. 1:11-CV-00983-AWI DLB
STIPULATION TO CONTINUE
DEADLINES TO DISCLOSE
EXPERTS AND TO FILE
DISPOSITIVE MOTIONS;
ORDER THEREON

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Plaintiff,
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vs.
ATTORNEYS AT LAW
2000 POWELL STREET, SUITE 900
EMERYVILLE, CALIFORNIA 94608
[phone]

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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THE AMERICAN INSURANCE
COMPANY and DOES 1 through 50,
inclusive,

Trial Date: December 2, 2012

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Defendants.
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STIPULATION TO CONTINUE DEADLINES
CASE NO. 1:11-CV-00983-AWI DLB

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TO THE HONORABLE DENNIS L. BECK, UNITED STATES DISTRICT COURT

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MAGISTRATE JUDGE:

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STIPULATION

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WHEREAS, Plaintiff THE MEAT MARKET, INC. and Defendant THE

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AMERICAN INSURANCE COMPANY desire to continue the parties’ last day to disclose

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expert witnesses and supplemental expert witnesses, and the parties’ last day to file

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dispositive motions, on the following grounds:
1.

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Counsel for both parties have worked diligently and amicably to complete

written discovery and schedule percipient depositions, but depositions and a site inspection

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are not yet complete;
2.

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Thus, counsel find that they cannot meet the existing deadlines for the

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ATTORNEYS AT LAW
2000 POWELL STREET, SUITE 900
EMERYVILLE, CALIFORNIA 94608
[phone]

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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parties’ disclosure of expert witnesses and supplemental expert witnesses, and for the

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filing of dispositive motions;
3.

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site inspection by July 20, 2012; and
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The parties have scheduled the completion of percipient depositions and a

This would be the first continuance of the dispositive motion deadline and

the second extension of the expert witness disclosure deadline in this matter.
NOW, THEREFORE, by and through their undersigned counsel of record, Plaintiff

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THE MEAT MARKET, INC. and Defendant THE AMERICAN INSURANCE

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COMPANY hereby stipulate to the following:

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1.

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continued to August 3, 2012;

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2.

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The last day for the parties to disclose expert witnesses with reports is

The last day for the parties to disclose supplemental expert witnesses

with reports is continued to August 17, 2012;
3.

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The last day for the parties to file dispositive motions is continued to

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August 10, 2012; and

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//
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STIPULATION TO CONTINUE DEADLINES
CASE NO. 1:11-CV-00983-AWI DLB

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4.

The last day for dispositive motions to be heard is continued to

September 17, 2012.

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DATED: June 15, 2012

FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC

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By:

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/s/ Kathleen M. DeLaney
Marjie D. Barrows
Kathleen M. DeLaney

Attorneys for Defendant
THE AMERICAN INSURANCE
COMPANY

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DATED: June 15, 2012, 2012

HOPPE LAW GROUP
By:

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ATTORNEYS AT LAW
2000 POWELL STREET, SUITE 900
EMERYVILLE, CALIFORNIA 94608
[phone]

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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/s/ Barbara J. Rueger
Theodore W. Hoppe
Barbara J. Rueger

Attorneys for Plaintiff
THE MEAT MARKET, INC., dba STATE
CENTER FOODS

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STIPULATION TO CONTINUE DEADLINES
CASE NO. 1:11-CV-00983-AWI DLB

ORDER

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IT IS HEREBY ORDERED, pursuant to the Stipulation of the parties, as follows:

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1.

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continued to August 3, 2012;

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2.

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3.

The last day for the parties to file dispositive motions is continued to

August 10, 2012; and
4.

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The last day for the parties to disclose supplemental expert witnesses

with reports is continued to August 17, 2012;

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The last day for the parties to disclose expert witnesses with reports is

The last day for dispositive motions to be heard is continued to

September 17, 2012.
IT IS SO ORDERED.

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ATTORNEYS AT LAW
2000 POWELL STREET, SUITE 900
EMERYVILLE, CALIFORNIA 94608
[phone]

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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Dated:

/s/ Dennis

June 19, 2012

L. Beck

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

3b142a

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STIPULATION TO CONTINUE DEADLINES
CASE NO. 1:11-CV-00983-AWI DLB