Hewitt, et al v. Zurich American Insurance, et al

Filing 11

STIPULATION and ORDER signed by Judge John A. Mendez on 1/23/2009 GRANTING 10 Stipulation and Proposed Order; Designation of Expert Witnesses due by 2/17/2009; Discovery due by 4/13/2009; Dispositive Motion due by 5/20/2009; Joint Pretrial Statement due by 7/17/2009; Pretrial Conference set for 7/24/2009 at 02:00 PM and Jury Trial set for 8/31/2009 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Matson, R)

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2000 Powell Street, Suite 1425, Emeryville, California 94608 Tel. No. [phone] Facsimile [phone]

Jonathan Gross, Esq. (SBN 122010) Jay E. Framson, Esq. (SBN 161931) BISHOP, BARRY, HOWE, HANEY & RYDER 2000 Powell Street, Suite 1425 Emeryville, California 94608 Telephone: [phone] Facsimile: [phone] Attorneys for MARYLAND CASUALTY COMPANY (also erroneously sued as Zurich American Insurance Group)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

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BISHOP, BARRY, HOWE, HANEY & RYDER

MATHEW J. HEWITT, ET AL., Plaintiff,

Case No. CV-08-01057-JAM-JFM STIPULATION FOR ENTRY OF MODIFIED SCHEDULING ORDER

A PROFESSIONAL CORPORATION

ZURICH AMERICAN INSURANCE GROUP, MARYLAND CASUALTY COMPANY Defendants.

Plaintiffs Matthew J. Hewitt and Pacific Crest Research Corporation, through their counsel of record Palmer Kazanjian Wohl Perkins LLP, and Defendant Maryland Casualty Company (also erroneously sued as Zurich American Insurance Group), through its counsel of record, Bishop, Barry, Howe, Haney & Ryder, hereby stipulate to the entry of a modified scheduling order to extend the deadlines for disclosure of expert witnesses, cutoff of non-expert discovery, and filing and hearing of dispositive motions for 30 days. Pursuant to the Court's July 21, 2008, Order, expert disclosures are due on January 16, 2009; non-expert discovery is to be completed by March 13, 2009; dispositive motions are to be filed by April 22, 2009; a Pretrial Conference is scheduled for June 26, 2009; and trial is scheduled for August 3, 2009. ///
1 STIPULATION FOR ENTRY OF MODIFIED SCHEDULING ORDER CASE NO.: CV-01057-JAM-JFM

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2000 Powell Street, Suite 1425, Emeryville, California 94608 Tel. No. [phone] Facsimile [phone]

This request is made in good faith and is not for the purpose of causing any undue delay. In particular, the parties are engaged in discussions that they hope will lead to a negotiated settlement of this case without the necessity of litigation. The parties therefore request that the Court enter a new scheduling order as follows: Expert witness disclosures Discovery Cutoff Dispositive motions to be filed Dispositive motions to be heard Joint pretrial statement Pretrial conference Jury trial Dated this 23rd day of January, 2009 ___________/s/______________________ Jonathan Gross Jay E. Framson BISHOP, BARRY, HOWE, HANEY & RYDER 2000 Powell Street, Suite 1425 Emeryville, CA 94608 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant MARYLAND CASUALTY COMPANY (also erroneously sued as Zurich American Insurance Group) February 17, 2009 April 13, 2009 May 20, 2009 June 17, 2009 at 9:00 a.m. July 17, 2009 July 24, 2009 at 2:00 p.m. August 31, 2009 at 9 a.m. Dated this 23rd day of January, 2009 ________/s/_________________________ Robin Perkins Robin K. Perkins Christopher F. Wohl PALMER KAZANJIAN WOHL PERKINS LLP 520 Capitol Mall, suite 600 Sacramento, CA 95814 Telephone: [phone] Fax: [phone] Attorneys for Plaintiffs MATTHEW HEWITT AND PACIFIC CREST RESEARCH CORPORATION

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BISHOP, BARRY, HOWE, HANEY & RYDER

A PROFESSIONAL CORPORATION

IT IS SO ORDERED: Dated: January 23, 2009 /s/ John A. Mendez JUDGE JOHN A. MENDEZ UNITED STATES DISTRICT JUDGE

2 STIPULATION TO EXTEND DISCOVERY CUTOFF AND EXPERT DISCLOSURES CASE NO.: CV-01057-JAM-JFM

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