County of Sacramento v. Turbomeca, S.A. et al

Filing 50

ORDER signed by Judge William B. Shubb on 07/17/09 GRANTING 49 Stipulation. IT IS ORDERED that the Initial Conference of the Parties shall occur no later than 11/6/09; Initial Disclosures of the parties shall occur no later than 12/4/09; and Status (Initial Scheduling) Conference is re-set for 12/14/2009 at 02:00 PM in Courtroom 5 (WBS) before Judge William B. Shubb. (Streeter, J)

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Ronald A. McIntire, Bar No. 127407 PERKINS COIE LLP 1888 Century Park E., Suite 1700 Los Angeles, CA 90067-1721 Telephone: [phone] Facsimile: 310.788.3399 Keith Gerrard (admitted pro hac vice) Richard Coyle (admitted pro hac vice) Brendan Murphy (admitted pro hac vice) PERKINS COIE LLP 1201 Third Avenue, Suite 4800 Seattle, WA 98101-3099 Telephone: [phone] Facsimile: 206.359.9000 Attorneys for Defendants Turbomeca S.A. and Turbomeca USA, Inc. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA OLD REPUBLIC INSURANCE COMPANY, Plaintiff, v. TURBOMECA S.A. and TURBOMECA USA, Defendants. COUNTY OF SACRAMENTO, Plaintiff, v. TURBOMECA S.A., a French Corporation; LA SOCIETE ANONYME TURBOMECA FRANCE, a French Corporation; TURBOMECA USA, a Texas Corporation; TURBOMECA ENGINE CORPORATION, a Texas Corporation, and Does 1 through 50, Defendants. Plaintiff County of Sacramento and Defendants Turbomeca S.A. (f/k/a La Societe Anonyme Turbomeca France) and Turbomeca USA, Inc. (f/k/a Turbomeca Engine Corporation) STIPULATION AND ORDER REGARDING EXTENSION OF TIME
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Case No. 2:07:CV-1398 WBS DAD [Consolidated Master Case Number] STIPULATION AND ORDER REGARDING EXTENSION OF TIME FOR RULE 26(F) CONFERENCE, TO SERVE INITIAL DISCLOSURES, AND TO CONTINUE INITIAL (PRETRIAL SCHEDULING) CONFERENCE

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hereby stipulate and seek an order of the Court extending certain deadlines in the above-entitled matter, and state as follows: These consolidated actions arise from the crash of a Sacramento County Sheriff's Department helicopter on July 13, 2005, which resulted in the deaths of two Sheriff's deputies, injuries to a third deputy, and the loss of the helicopter. The County of Sacramento commenced the action numbered 2:07-cv-01398-WBS-DAD on July 13, 2007. Old Republic Insurance Company commenced the action numbered 2:08-cv-01376-WBS-DAD on June 18, 2008. The damages sought by plaintiffs include property loss, reimbursement of insurance payments for the helicopter, reimbursement of workers' compensation payments made to, or on behalf of, the occupants of the helicopter, and loss of use. The helicopter occupants and their families commenced a separate personal injury action against Turbomeca S.A. and Turbomeca USA, but the parties to that action reached a settlement and the case has been dismissed.1 On August 7, 2008, the Court ordered the actions consolidated under master case number 07-CV-01398-WBS-DAD. The court also adopted the scheduling order from the Old Republic action, which set a status conference for December 1, 2008, at 2:00 p.m. On November 17, 2008, the Court continued this conference to April 6, 2009. (Docket No. 43.) On March 19, 2009, the Court continued this conference to September 8, 2009. (Docket No. 47.) The defendants have filed their answers in these consolidated actions and the parties have been working diligently to resolve the case informally and without burden on the Court. Counsel for Old Republic and Turbomeca met in person in June 2009 and settled the claims brought by Old Republic. (Notice of Settlement, Docket No. 48.) Counsel for Turbomeca and the County have met in person to discuss resolution of the case and are scheduling additional meetings in person, which will likely occur in August or September 2009. The parties have also been in the process of informally exchanging documents and information and have exchanged and are reviewing numerous documents. The parties mutually desire to avoid unnecessary litigation and expense, and to facilitate an early and cost-effective resolution of these consolidated cases.
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Eric Henrikson, et al. v. Turbomeca, S.A., et al., Case No. 2:06-cv-01563-WBS-DAD (filed July 13, 2006, terminated June 26, 2008).

STIPULATION AND ORDER REGARDING EXTENSION OF TIME
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The parties respectfully submit, by this Stipulation, their joint request that all currently scheduled matters in this action be continued for a period of four months, so that the parties can continue the informal exchange of information and documents and work toward an informal resolution of the cases without incurring unnecessary expenses and without imposing any unnecessary burdens on the Court. Accordingly, the parties hereby STIPULATE AND AGREE to submit their joint request that the Court order as follows: 1) That the deadline for completion of the Rule 26(f) conference of the parties is

extended a date no later than November 6, 2009; 2) 4, 2009; and 3) That the initial scheduling conference currently set for September 8, 2009 is That the deadline for the exchange of initial disclosures is extended to December

continued to a date no earlier than December 18, 2009. DATED: _July 17________, 2009 PERKINS COIE LLP By: /s/Brendan Murphy Brendan Murphy

Attorneys for Defendants Turbomeca S.A. and Turbomeca USA, Inc. DATED: _July 17________, 2009 LENAHAN, LEE SLATER & PEARSE, LLP By: /s/Kathleen Staker per email approval Charleton S. Pearse Kathleen Staker

Attorneys for Plaintiff County of Sacramento

STIPULATION AND ORDER REGARDING EXTENSION OF TIME
24839-0159/LEGAL16553620.1

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND ORDER REGARDING EXTENSION OF TIME
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ORDER IT IS HEREBY ORDERED THAT: (1) The Initial Conference of the Parties pursuant to Federal Rule of Civil

Procedure 26(f) shall occur no later than November 6, 2009; (2) The Initial Disclosures of the parties pursuant to Federal Rule of Civil

Procedure 26(a)(1) shall occur no later than December 4, 2009; and (3) The Status (Initial Scheduling) Conference currently scheduled for September 8,

2009 is vacated and rescheduled for December 14, 2009, at 2pm.

DATED: July 17, 2009

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