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

Filing 37

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 7/23/13 ORDERING that the Discovery due date is moved to 8/2/2013. (Manzer, C)

1 McCormick, Barstow, Sheppard,
Wayte & Carruth LLP
2 Patrick Fredette, #207284
[e-mail]
3 Scripps Center, Suite 1050
312 Walnut Street
4 Cincinnati, OH 45202
Telephone:
[phone]
5 Facsimile:
[phone]
6 McCormick, Barstow, Sheppard,
Wayte & Carruth LLP
7 Jay A. Christofferson, #203878
[e-mail]
8 5 River Park Place East
Fresno, California 93720-1501
9 Telephone:
[phone]
Facsimile:
[phone]
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Attorneys for Plaintiff
11 National Union Fire Insurance Company of
Pittsburgh, PA.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION
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NATIONAL UNION FIRE INSURANCE
16 COMPANY OF PITTSBURGH, PA, a
Pennsylvania corporation,
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Plaintiff,
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v.
19
ALLIED PROPERTY AND CASUALTY
20 INSURANCE COMPANY, an Iowa
corporation,
21
Defendant.
22

Case No. 2:12-cv-01380-MCE-KJN
AMENDED STIPULATION AND ORDER
TO CONTINUE DISCOVERY CUTOFF

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MCCORMICK, BARSTOW ,
SHEPPARD, WAYTE &
CARRUTH LLP
5 RIVER PARK PLACE EAST
FRESNO, CA 93720-1501

2:12-cv-01380-MCE-KJN
AMENDED STIPULATION AND ORDER TO CONTINUE DISCOVERY CUTOFF

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The parties, by and through their attorneys of record, hereby request a short continuance of the

2 discovery cutoff to allow completion of discovery properly noticed and served so as to comply with
3 the original discovery cutoff of June 14, 2013. The parties request the discovery cutoff be extended to
4 August 2, 2013, an additional 21 days from the present deadline of July 12. This extension will not
5 affect or interfere with any other dates scheduled by the Court, such as the deadline for dispositive
6 motions or the trial date. This is the third request made by the parties in this action and the discovery
7 cutoff has previously been extended a total of 29 days.
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Good cause exists to allow a short continuance of the discovery cutoff. Although the parties

9 have managed to informally resolve the majority of their discovery disputes, one dispute had to be
10 decided by motion. On July 5, 2013, the Court ruled on that motion, and the additional time requested
11 is necessary to prepare for and conduct the remaining discovery.
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For these reasons, the parties respectfully request that the current discovery cutoff of July 12,

13 2013, be extended to August 2, 2013.
14 Dated: July 12, 2013
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McCORMICK, BARSTOW, SHEPPARD,
WAYTE & CARRUTH LLP

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21 Dated: July 12, 2013

/s/ Jay A. Christofferson
Patrick Fredette
Jay A. Christofferson
Attorneys for Plaintiff
National Union Fire Insurance Company of Pittsburgh,
PA.
By:

MECKLER BULGER TILSON MARICK &
PEARSON LLP

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/s/ Renee C. Callantine
Karen L. Uno
Renee C. Callantine
Attorneys for Defendant
Allied Property and Casualty Insurance Company
By:

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MCCORMICK, BARSTOW ,
SHEPPARD, WAYTE &
CARRUTH LLP
5 RIVER PARK PLACE EAST
FRESNO, CA 93720-1501

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PROOF OF SERVICE

2:12-cv-01380-MCE-KJN

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ORDER
GOOD CAUSE APPEARING, it is ordered that the discovery cutoff presently set for July 12,

3 2013, is moved to August 2, 2013. All other dates established by the Court’s Scheduling Order
4 remain in effect.
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IT IS SO ORDERED.

6 Dated: July 23, 2013
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MCCORMICK, BARSTOW ,
SHEPPARD, WAYTE &
CARRUTH LLP
5 RIVER PARK PLACE EAST
FRESNO, CA 93720-1501

2:12-cv-01380-MCE-KJN
AMENDED STIPULATION AND ORDER TO CONTINUE DISCOVERY CUTOFF