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

Filing 23

STIPULATION and ORDER to Continue Trial Date and Pretrial Deadlines, signed by Chief Judge Anthony W. Ishii on 8/13/2012. (1. The discovery cut-off for percipient depositions already noticed and a site inspection is continued to 11/2/2012; 2. The last day for the parties to disclose expert witnesses with reports is continued to November 23, 2012; 3. The last day for the parties to disclose supplemental expert witnesses with reports is continued to 12/7/2012; 4. The last day for dispositive mo tions to be heard is continued to 2/22/2013; 5. Final Pretrial Conference is CONTINUED to 4/5/2013 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii; & 6. Jury Trial is CONTINUED to 5/23/2013 at 08:30 AM in Courtroom 2 (AWI) before Chief Judge Anthony W. Ishii.)(Gaumnitz, R)

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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,

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No. 1:11-CV-00983-AWI DLB
STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND
PRE-TRIAL DEADLINES

Plaintiff,

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

Trial Date: December 2, 2012

Defendants.
/

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STIPULATION AND ORDER TO CONTINUE TRIAL
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 trial date and all related

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pre-trial dates in this matter, on the following grounds:

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1.

Counsel for both parties have worked diligently and amicably to complete

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

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are not yet complete.

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2.

As set forth in detail in the declaration of Theodore W. Hoppe, counsel for

Plaintiff have more than 15 trials in other matters set for August, September, November

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and December 2012, and due to scheduling and preparation issues related to the other

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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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trials, counsel find that they cannot meet the existing deadlines and adequately prepare for

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trial in this matter.

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3.

This would be the first trial continuance in this matter.

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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.

inspection is continued to November 2, 2012;

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2.

3.

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The last day for the parties to disclose supplemental expert witnesses with
reports is continued to December 7, 2012;

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The last day for the parties to disclose expert witnesses with reports is
continued to November 23, 2012;

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The discovery cut-off for percipient depositions already noticed and a site

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The last day for dispositive motions to be heard is continued to February 22,
2013;

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STIPULATION AND ORDER TO CONTINUE TRIAL
CASE NO. 1:11-CV-00983-AWI DLB

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5.

The final pre-trial conference is continued to April 5, 2013; and

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6.

The trial date is continued to May 13, 2013.

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DATED: August 10, 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: August 10, 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/ Theodore W. Hoppe
Theodore W. Hoppe
Barbara J. Rueger

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

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STIPULATION AND ORDER TO CONTINUE TRIAL
CASE NO. 1:11-CV-00983-AWI DLB

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ORDER

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

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1.

The discovery cut-off for percipient depositions already noticed and a site
inspection is continued to November 2, 2012;

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2.

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The last day for the parties to disclose expert witnesses with reports is
continued to November 23, 2012;

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3.

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The last day for the parties to disclose supplemental expert witnesses with
reports is continued to December 7, 2012;

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4.

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The last day for dispositive motions to be heard is continued to February 22,
2013;

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5.

The final pre-trial conference is continued to April 5, 2013 at 8:30am; and

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6.

The trial date is continued to May 23, 2013 at 8:30am.

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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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IT IS SO ORDERED.
Dated: August 13, 2012
CHIEF UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:

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0m8i788

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STIPULATION AND ORDER TO CONTINUE TRIAL
CASE NO. 1:11-CV-00983-AWI DLB