Raymond Muro et al v. Travelers Commercial Insurance Company

Filing 13

STIPULATION and ORDER TO EXTEND CERTAIN PRE-TRIAL DEADLINES; Designation of Expert Witnesses due by 3/30/2018, Rebuttal 4/13/2018; Non-Expert Discovery due by 3/9/2018, Expert 4/23/2018; Non-Dispositive Motions filed by 5/7/2018, signed by Magistrate Judge Michael J. Seng on 11/21/2017. (Bernacchi, M)

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MARJIE D. BARROWS (State Bar No. 122129)
KATHLEEN M. DeLANEY (State Bar No. 196376)
FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC
2000 Powell Street, Suite 900
Emeryville, CA 94608
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]

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Attorneys for Defendant TRAVELERS
COMMERCIAL INSURANCE COMPANY

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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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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RAYMOND MURO, an individual, and
LUPE MURO, an individual,

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Plaintiffs,

CASE NO. 1:17-CV-00170-LJO-MJS
STIPULATION TO EXTEND
CERTAIN PRE-TRIAL DEADLINES

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vs.
Complaint Filed: February 7, 2017

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TRAVELERS COMMERCIAL
INSURANCE COMPANY, and DOES 1
through 10,

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Defendants.
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Plaintiffs RAYMOND MURO, an individual, and LUPE MURO, an individual (collectively

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“Plaintiffs”) and Defendant TRAVELERS COMMERCIAL INSURANCE COMPANY

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(“Travelers”), by and through their respective counsel, hereby submit this Stipulation and Proposed

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Order for a continuance of certain pre-trial deadlines

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WHEREAS, the Scheduling Order dated May 11, 2017 set a trial date of September 11,
2018 and attendant pre-trial deadlines;
WHEREAS, the parties desire to participate in a meaningful mediation prior to completing
percipient discovery and incurring costs associated with expert discovery;
WHEREAS, because of scheduling conflicts, the parties cannot complete mediation until
January 2018;

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-1STIPULATION TO EXTEND DEADLINES – CASE NO. 1:17-CV-00170-LJO-MJS

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WHEREAS, the parties wish to continue pre-trial deadlines to permit them to mediate this
matter before completing percipient discovery and before the parties incur costs associated with
expert discovery;
WHEREAS, this is the first continuance that the parties have requested;
WHEREAS, the parties’ counsel have conferred and stipulated to a continuance of the dates
set forth in the Scheduling Order as follows:

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Discovery Deadlines:
Non-Expert: 3/9/2018
Expert: 4/23/2018

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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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Expert Disclosure Deadlines:
Filing: 3/30/2018
Supplemental/Rebuttal: 4/13/2018

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Motion Deadlines:
Non-Dispositive:
Filing: 5/7/2018
Hearing: To Be Determined
Dispositive:
Filing: 5/11/2018
Hearing: 6/26/2018 at 8:30 AM
NOW THEREFORE, it is stipulated that the parties agree to continue certain pre-trial
deadlines as set forth above

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DATED: November 21, 2017
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FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC

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By:

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

Attorneys for Defendant TRAVELERS
COMMERCIAL INSURANCE COMPANY

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DATED: November 21, 2017

KERLEY SCHAFFER LLP

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By:

/s/ J. Edward Kerley
J. Edward Kerley
Dylan L. Schaffer

Attorneys for Plaintiffs RAYMOND and
LUPE MURO
-2STIPULATION TO EXTEND DEADLINES – CASE NO. 1:17-CV-00170-LJO-MJS

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ORDER

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The Court has considered the above Stipulation to Continue Certain Pre-trial

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Deadlines. Given this Court’s policy of not changing dispositive motion deadlines or

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pretrial conference and trial dates, but good cause appearing for modifying earlier

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pretrial dates and deadlines,
IT IS HEREBY ORDERED THAT:

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The Scheduling Order is modified so that the deadlines in this matter are as follows:

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Discovery Deadlines:
Non-Expert: 3/9/2018
Expert: 4/23/2018

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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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Expert Disclosure Deadlines:
Filing: 3/30/2018
Supplemental/Rebuttal: 4/13/2018

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Non-Dispositive Motion Deadline:
Filing: 5/7/2018
Hearing: To Be Determined

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The Deadline for filing and hearing dispositive motions shall remain April 13,

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2018 and May 29, 2018, respectively, the Pretrial Conference will remain as
scheduled on July 17, 2018, and trial shall begin on September 11, 2018, as

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previously scheduled.

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IT IS SO ORDERED.

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Dated:
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November 21, 2017

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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-3STIPULATION TO EXTEND DEADLINES – CASE NO. 1:17-CV-00170-LJO-MJS