National Union Fire Insurance Company of Pittsburgh, PA v. Allied Property and Casualty Insurance Company

Filing 26

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 6/10/2013 re: 25 Stipulation and Proposed Order ORDERING Hearing CONTINUED to 6/20/2013 at 10:00 AM in Courtroom 25 (KJN) before Magistrate Judge Kendall J. Newman. (Waggoner, D)

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Karen L. Uno (State Bar No. 117410)
[e-mail]
Renée C. Callantine (State Bar No. 155991)
[e-mail]
MECKLER BULGER TILSON MARICK & PEARSON LLP
575 Market Street, Suite 2200
San Francisco, CA 94105
TEL: [phone] FAX: [phone]

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Attorneys for Defendant
ALLIED PROPERTY AND CASUALTY
INSURANCE COMPANY

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MECKLER BULGER TILSON MARICK & PEARSON LLP

UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, PA, a
Pennsylvania corporation,

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Plaintiff,
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vs.

CASE NO.: 2:12-CV-01380-MCE- KJN
STIPULATION AND ORDER RE
CONTINUANCE OF ALLIED PROPERTY
AND CASUALTY INSURANCE
COMPANY’S MOTION TO COMPEL
DEPOSITION AND DOCUMENTS

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ALLIED PROPERTY AND CASUALTY
INSURANCE COMPANY, an Iowa
corporation,

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DATE:
TIME:
ROOM.:
JUDGE:

June 11, 2013
8:30 a.m.
25, 8th Floor
Kendall J. Newman

Defendants.
FILE DATE:
TRIAL DATE:

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May 22, 2012
April 14, 2014

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The parties, by and through their attorneys, hereby request a continuance of Allied
Property and Casualty Insurance Company’s (“Allied”) Motion to Compel the Deposition of
National Union Fire Insurance Company of Pittsburgh, PA (“National Union”) and the Motion to
Compel Further Production of Documents currently set for June 11, 2013 at 8:30 a.m. to June 20,
2013 at 10:00 a.m.
Good cause exists to allow a continuance. The parties had believed they reached an
impasse and the motions were filed. The parties have had continued talks and, through them,
12-1380 National Union v. Allied Stip and
Order re Continuance of Discovery
Motion Hearing Date.docx
STIPULATION AND ORDER RE CONTINUANCE OF ALLIED PROPERTY AND CASUALTY INSURANCE
COMPANY’S MOTION TO COMPEL DEPOSITION AND DOCUMENTS

resolved most of the issues in dispute with regard to the respective Motions. The parties believe

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they have resolved the dispute with respect to the Motion to Compel the Deposition, although

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complete resolution may be impacted by the ability to resolve the issues with regard to the

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Motion to Compel Further Production of Documents. The parties have resolved most issues with

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regard to the Motion to Compel Further Production of Documents. There remains an issue as to

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the scope of production of the requested documents. The parties are hopeful that they will resolve

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the remaining issue on scope of production in the next day or two. However, because of the

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MECKLER BULGER TILSON MARICK & PEARSON LLP

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impending discovery deadline, the Parties seek to continue the hearing on the motions to June 20,

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2013 pending resolution of the remaining dispute.

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For these and other valid reasons, the parties respectfully request that the hearing of June
11, 2013 be continued to June 20, 2013.

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Dated: June 10, 2013

MECKLER BULGER TILSON MARICK &
PEARSON LLP

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By: /s/ Renée C. Callantine
Karen L. Uno
Renée C. Callantine
Attorneys for Defendant
ALLIED PROPERTY AND CASUALTY
INSURANCE COMPANY

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Dated: June 10, 2013

MCCORMICK, BARSTOW, SHEPPARD,
WAYTE & CARRUTH LLP

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By: /s/ Patrick Fredette
Patrick Fredette
Jay A. Christofferson
Attorneys for Plaintiff
NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, PA

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Union v. Allied Stip and
Order re Continuance of Discovery
Motion Hearing Date.docx

12-1380 National

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STIPULATION AND ORDER RE CONTINUANCE OF ALLIED PROPERTY AND CASUALTY INSURANCE
COMPANY’S MOTION TO COMPEL DEPOSITION AND DOCUMENTS

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ORDER

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GOOD CAUSE APPEARING, it is ordered that the hearing, currently set for June 11,
2013, is moved to June 20, 2013 at 10:00 a.m.

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Date: 6/10/2013

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_____________________________________
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE

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MECKLER BULGER TILSON MARICK & PEARSON LLP

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DEAC_Signature-END:

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Union v. Allied Stip and
Order re Continuance of Discovery
Motion Hearing Date.docx

12-1380 National

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STIPULATION AND ORDER RE CONTINUANCE OF ALLIED PROPERTY AND CASUALTY INSURANCE
COMPANY’S MOTION TO COMPEL DEPOSITION AND DOCUMENTS