Tucker v. AMCO Insurance Company

Filing 16

STIPULATION and ORDER TO CONTINUE DISCOVERY AND EXPERT DISCLOSURE DEADLINES AND TRIAL DATE; Settlement Conference set for 6/13/2019 at 01:00 PM in Courtroom 10 (EPG) before Magistrate Judge Erica P. Grosjean. Pretrial Conference set for 7/9/201 9 at 01:30 PM in Courtroom 5 (DAD) before District Judge Dale A. Drozd., Jury Trial set for 9/24/2019 at 01:30 PM in Courtroom 5 (DAD) before District Judge Dale A. Drozd, signed by Magistrate Judge Sheila K. Oberto on 10/26/2018. (Kusamura, W)

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MATTHEW S. FOY (SBN: 187238)
[e-mail]
JENNIFER N. WAHLGREN (SBN: 249556)
[e-mail]
GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
AMCO INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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JENNIFER MARIE TUCKER,

)
)
Plaintiff,
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vs.
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AMCO INSURANCE COMPANY, and Does 1 )
through 25, inclusive,
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)
Defendants
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CASE NO. 1:17-cv-01761-DAD-SKO
STIPULATION TO CONTINUE
DISCOVERY AND EXPERT
DISCLOSURE DEADLINES; ORDER
(Doc. 15)
State Court Complaint Filed:
November 17, 2017
Removal Filed: January 28, 2017

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Plaintiff Jennifer Marie Tucker (“Plaintiff”) and Defendant AMCO Insurance Company
(“AMCO”) (collectively, the “Parties”) stipulate as follows:

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WHEREAS, the Scheduling Order filed in this case (ECF No. 11) sets forth the following
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deadlines:
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Discovery Deadlines:
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Non-Expert:

12/4/18

Expert:

1/18/19

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Expert Disclosure Deadlines:
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Filing:

12/18/18

Supplemental/Rebuttal:

1/2/19

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-1STIPULATION TO CONTINUE DISCOVERY AND EXPERT DISCLOSURE DEADLINES;
ORDER

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WHEREAS, the Parties agree that the foregoing discovery and expert disclosure deadlines

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should be continued by two months to allow additional time for the Parties to complete discovery

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while also permitting more time for the Parties to discuss possible resolution of the claims at issue

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in this litigation.

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WHEREAS, the Parties are not requesting any continuance of any of the other deadlines
or trial date in connection with this litigation.

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THEREFORE, IT IS HEREBY STIPULATED AND AGREED:

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The Scheduling Order should be amended to set forth the following new deadlines for

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Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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discovery and expert disclosures, which extend those deadlines by two months:
Discovery Deadlines:

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Non-Expert:

2/4/19

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Expert:

3/18/19

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Expert Disclosure Deadlines:

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Filing:

2/20/19

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Supplemental/Rebuttal:

3/4/19

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SO STIPULATED.

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Dated: October 23, 2018

WILKINS, DROLSHAGEN & CZESHINSKI LLP

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By /s/ James H. Wilkins (as authorized on 10/23/18)
James H. Wilkins
Attorneys for Plaintiff
JENNIFER MARIE TUCKER

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Dated: October 23, 2018

GORDON REES SCULLY MANSUKHANI, LLP

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By /s/ Jennifer N. Wahlgren
Matthew S. Foy
Jennifer N. Wahlgren
Attorneys for Defendant
AMCO INSURANCE COMPANY
-2STIPULATION TO CONTINUE DISCOVERY AND EXPERT DISCLOSURE DEADLINES;
ORDER

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ORDER

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Based in part on the parties’ above-stipulation (Doc. 15), and with good cause shown, the
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Court hereby ORDERS that the Scheduling Order (Doc. 11) is modified as follows:1

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Event

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Prior Date

Continued Date

Non-Expert Discovery Completion December 4, 2018

Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

March 4, 2019

January 18, 2019

March 18, 2019

January 18, 2019

March 20, 2019

Non-Dispositive Motion Hearing

None set

April 17, 2019

Dispositive Motion Filing

February 1, 2019

April 2, 2019

Dispositive Motion Hearing

March 19, 2019

May 21, 2019

Settlement Conference

None set

Pretrial Conference

June 4, 2019, 1:30 pm

June 13, 2019, 1:00 pm in
Courtroom 10 before
United States Magistrate
Judge Erica P. Grosjean2
July 29, 2019, at 1:30 pm

Trial

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January 2, 2019

Non-Dispositive Motion Filing

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February 20, 2019

Expert Discovery Completion

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December 18, 2018

Rebuttal Expert Disclosures

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February 4, 2019

Expert Disclosures

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August 20, 2019, 1:00
p.m.

September 24, 2019, at
8:30 a.m.

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IT IS SO ORDERED.

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Dated:

October 26, 2018

/s/

Sheila K. Oberto

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UNITED STATES MAGISTRATE JUDGE

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Several of the dates proposed by the parties have been adjusted to comport with the Court’s calendar, to allow the
Court adequate time to rule on dispositive motions, and to permit the parties sufficient time to prepare their pretrial
submissions and for trial.
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Settlement conferences are required in all cases in which District Judge Drozd is the presiding judge.
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-3STIPULATION TO CONTINUE DISCOVERY AND EXPERT DISCLOSURE DEADLINES;
ORDER