Tucker v. AMCO Insurance Company

Filing 25

STIPULATION and ORDER TO CONTINUE EXPERT DISCOVERY AND DISCLOSURE DEADLINES: Expert Disclosures ddl 3/20/2019; Rebuttal Expert Disclosures ddl 4/4/2019; Expert Discovery Completion due by 3/20/2019; Non-Dispositive & Dispositive Motions filed by 4/24/2019; Pretrial Conference set for 8/12/2019 at 01:30 PM and Jury Trial set for 10/8/2019 at 08:30 AM in Courtroom 5 (DAD) before District Judge Dale A. Drozd, signed by Magistrate Judge Sheila K. Oberto on 2/13/2019. (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,

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Plaintiff,
vs.
AMCO INSURANCE COMPANY, and Does 1
through 25, inclusive,

CASE NO. 1:17-cv-01761-DAD-SKO
STIPULATION TO CONTINUE
EXPERT DISCOVERY AND
DISCLOSURE DEADLINES; ORDER
(Doc. 24)

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Defendants
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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 current Scheduling Order in this case (ECF No. 16) sets forth the
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following deadlines relating to Expert Disclosures and Expert Discovery:
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Expert Disclosures:

February 20, 2019

Rebuttal Expert Disclosures:

March 4, 2019

Expert Discovery Completion:

March 18, 2019

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WHEREAS, the Parties agree that the foregoing deadlines should be continued by
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approximately one month to allow additional time for the Parties to complete pending 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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-1STIPULATION TO CONTINUE EXPERT DISCLOSURE AND DISCOVERY DEADLINES;
ORDER

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WHEREAS, the Parties are not requesting any continuance of any of the other deadlines

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or trial date in connection with this litigation. The Parties request that all other dates and deadlines

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as set forth in in the current Scheduling Order (ECF No. 16) remain the same.

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THEREFORE, IT IS HEREBY STIPULATED AND AGREED:

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The current Scheduling Order (ECF No. 16) should be amended to set forth the following

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new deadlines relating to Expert Disclosures and Expert Discovery:

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Expert Disclosures:

March 20, 2019

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Rebuttal Expert Disclosures:

April 4, 2019

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Expert Discovery Completion:

April 18, 2019

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

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SO STIPULATED.

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Dated: February 11, 2019

WILKINS, DROLSHAGEN & CZESHINSKI LLP

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By /s/ James H. Wilkins (as authorized on 2/11/19)
James H. Wilkins
Attorneys for Plaintiff
JENNIFER MARIE TUCKER

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Dated: February 11, 2019

GORDON REES SCULLY MANSUKHANI, LLP

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By /s/ Matthew S. Foy
Matthew S. Foy
Jennifer N. Wahlgren
Attorneys for Defendant
AMCO INSURANCE COMPANY

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-2STIPULATION TO CONTINUE EXPERT DISCLOSURE AND DISCOVERY DEADLINES;
ORDER

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ORDER

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Based in part on the parties’ second stipulation (Doc. 24), and with good cause shown, the
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Court hereby ORDERS that case schedule (Doc. 16) is modified as follows:1

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Event

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

April 4, 2019

March 18, 2019

April 18, 2019

March 20, 2019

April 24, 2019

April 17, 2019

May 22, 2019

Dispositive Motion Filing

April 2, 2019

April 24, 2019

Dispositive Motion Hearing

May 21, 2019

June 4, 2019

Pretrial Conference

July 29, 2019, at 1:30 pm

Trial

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March 4, 2019

Non-Dispositive Motion Hearing

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March 20, 2019

Non-Dispositive Motion Filing

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February 20, 2019

Expert Discovery Completion

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Continued Date

Rebuttal Expert Disclosures

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Prior Date

Expert Disclosures

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

August 12, 2019, at 1:30
pm
October 8, 2019, at 8:30
a.m.

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IT IS SO ORDERED.

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Dated:

February 13, 2019

/s/

Sheila K. Oberto

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UNITED STATES MAGISTRATE JUDGE

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The Court notes that the parties request that all dates and deadlines, other than those pertaining to experts, remain
the same. Granting this request, however, would be problematic: if so, the parties’ deadline to conduct expert
discovery would occur after the deadlines for filing non-dispositive and non-dispositive motions. Accordingly, the
Court has enlarged these deadlines, as well as the pretrial conference and trial, to allow the parties adequate time to
file, and for the Court to rule on, motions, and to permit the parties sufficient time to prepare their pretrial submissions
and for trial.

-3STIPULATION TO CONTINUE EXPERT DISCLOSURE AND DISCOVERY DEADLINES;
ORDER