Pacific Marine Center, Inc. et al v. Philadelphia Indemnity Insurance Company

Filing 40

STIPULATION and ORDER re DISCOVERY CUT-OFF and AMENDMENT OF SCHEDULING ORDER. Based on the parties' foregoing stipulation and the supplemental statement filed on May 5, 2015, the Court modifies the Scheduling Order dated November 26, 20 13. Accordingly, discovery deadlines and motion filing deadlines are continued as follows: Non Expert Discovery cutoff: September 15, 2015. Expert Disclosure: September 11, 2015. Supplemental Expert Disclosure: September 25, 2015. Expert Discovery cutoff: October 30, 2015. Settlement Conference set for June 30, 2015, at 10:00 AM in Courtroom 8 (BAM) before Magistrate Judge Barbara A. McAuliffe. Non Dispositive Motions: Filing: October 27, 2015. Dispositive Motions: Filing: October 27, 2015. Pretrial Conference set for January 27, 2016, at 08:30 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii. Trial set for March 22, 2016, at 08:30 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii. Order signed by Magistrate Judge Sheila K. Oberto on 5/7/2015. (Timken, A)

Bruce T. Smyth- State Bar No. 89171
CHARLSTON, REVICH & WOLLITZ LLP
2 1925 Century Park East, Suite 1250
Los Angeles, California 90067-2746
3 Tel: [phone] • Fax: [phone]
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Attorneys for Defendant,
Philadelphia Indemnity Insurance Company

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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PACIFIC MARINE CENTER, INC., a
California corporation, and SONA
12 VARTANIAN, an individual,
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Plaintiffs,

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v.

PHILADELPHIA INDEMNITY
INSURANCE COMPANY, a
16 Pennsylvania corporation, and DOES
1 through 10, inclusive,
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Case No. 1:13-CV-00992-AWI-SKO
STIPULATION AND
[PROPOSED] ORDER RE
DISCOVERY CUT-OFF AND
AMENDMENT OF SCHEDULING
ORDER

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Defendants.

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WHEREAS, that the parties through their counsel have mutually agreed to

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request that the discovery cutoff and other deadline dates set forth in the case

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original Scheduling Order and Order Amending Scheduling Order be continued in

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order to allow additional time for completing depositions and other discovery,

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while accommodating the respective schedules of counsel;

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WHEREAS, the parties have met and conferred regarding discovery and will

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meet further regarding the respective schedules of counsel in this matter, because

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the parties would like to provide for more time to allow the necessary remaining

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STIPULATION AND ORDER RE DISCOVERY CUT-OFF AND AMENDING SCHEDULING ORDER

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discovery to be conducted while accommodating the schedules of counsel. The

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continuance of discovery cut-off dates would allow this to be accomplished. The

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parties believe that such extension is advantageous to both parties and allows for

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the best use of time and resources.

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WHEREAS, after meeting and conferring, the counsel have agreed to
approximate three month extensions of the scheduling dates;
NOW, THEREFORE, it is hereby stipulated by Plaintiffs and Defendant, by
and through their respective counsel of record, as follows:
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The various deadlines for discovery and pre-trial and trial dates

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currently set shall be continued for some three months to the following dates, or

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such other dates in reasonable proximity thereto convenient to the Court’s schedule,

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as follows:

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Non Expert Discovery cutoff: September 15, 2015.

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Expert Disclosure: September 11, 2015.

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Supplemental Expert Disclosure: September 25, 2015.

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Expert Discovery cutoff: October 30, 2015.

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Settlement Conference: June 30, 2015, at 10:00 a.m., Courtroom 8.

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Non Dispositive Motions:

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Filing: October 27, 2015.

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Hearing: November 30, 2015.
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Dispositive Motions:

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Filing: October 27, 2015

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Hearing: December 15, 2015.

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Pre-Trial Conference: January 25, 2016, at 8:30 a.m., Courtroom 2.

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Trial: March 21, 2016, at 8:30 a.m., Courtroom 2.

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2.

The Case Scheduling Order, dated November 26, 2013, the Order Re

Discovery Cut-Off and Amending Scheduling Order, signed October 2, 2015, and
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STIPULATION AND ORDER RE DISCOVERY CUT-OFF AND AMENDING SCHEDULING ORDER

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the Order re Discovery Cut-Off and Amendment of Scheduling Order, signed

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March 9, 2015, shall be amended to reflect the new dates.

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Dated: April 27, 2015

THE REICH LAW FIRM

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By:

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/s/ Jeff Reich
Jeff Reich
Attorneys for Plaintiffs

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Dated: April 27, 2015

CHARLSTON, REVICH & WOLLITZ LLP
By:

/s/ Bruce T. Smyth
Bruce T. Smyth
Attorneys for Defendant

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STIPULATION AND ORDER RE DISCOVERY CUT-OFF AND AMENDING SCHEDULING ORDER

ORDER

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Based on the parties’ foregoing stipulation and the supplemental statement

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filed on May 5, 2015, the Court modifies the Scheduling Order dated November 26,

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2013.

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Accordingly, discovery deadlines and motion filing deadlines are continued
as follows:1

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Non Expert Discovery cutoff: September 15, 2015

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Expert Disclosure: September 11, 2015

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Supplemental Expert Disclosure: September 25, 2015

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Expert Discovery cutoff: October 30, 2015

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Settlement Conference: June 30, 2015, at 10:00 a.m., Courtroom 8

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Non Dispositive Motions:

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Filing: October 27, 2015

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Hearing: November 25, 2015

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Dispositive Motions:

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Filing: October 27, 2015

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Hearing: December 14, 2015

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Pre-Trial Conference: January 27, 2016, at 8:30 a.m., Courtroom 2
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Trial: March 22, 2016, at 8:30 a.m., Courtroom 2

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IT IS SO ORDERED.

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Dated:

May 7, 2015

/s/ Sheila K. Oberto

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UNITED STATES MAGISTRATE JUDGE

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Some of the proposed dates were modified slightly to conform with the Court's calendars.

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STIPULATION AND ORDER RE DISCOVERY CUT-OFF AND AMENDING SCHEDULING ORDER