Trujillo et al v. Nationwide Mutual Insurance Company et al

Filing 28

ORDER signed by Chief Judge Morrison C. England, Jr on 4/22/14 AMENDING 25 Scheduling Order to extend the fact discovery completion date from 4/9/14 to 5/30/14 re: 26 . (Meuleman, A)

1 WALKUP, MELODIA, KELLY & SCHOENBERGER
Richard H. Schoenberger, SBN: 122190
2 Spencer J. Pahlke, SBN: 250914
650 California Street, 26th Floor
3 San Francisco, CA 94108
Telephone: [phone]
4 Facsimile: [phone]
Email: [e-mail]
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MEREDITH, WEINSTEIN & NUMBERS, LLP
115 WARD STREET
LARKSPUR, CALIFORNIA 94939

6 MEREDITH, WEINSTEIN & NUMBERS, LLP
Barron L. Weinstein, SBN: 067972
7 115 Ward Street
Larkspur, CA 94939
8 Telephone: [phone]
Facsimile: [phone]
9 Email: [e-mail]
10 Attorneys for Plaintiffs
Pascual Trujillo, Leticia Trujillo,
11 and Gregory Trujillo
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UNITED STATES DISTRICT COURT FOR THE

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EASTERN DISTRICT OF CALIFORNIA

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16 Pascual Trujillo, Leticia Trujillo, and Gregory
Trujillo,
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Plaintiffs,

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19 v.

20 Nationwide Insurance Company of America,
Nationwide Mutual Insurance Company,
21 Nationwide Sales Solutions, Inc., and DOES 150, Inclusive,
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CASE NO.: 2:12-CV-02958 MCE CMK
STIPULATION AND REQUEST TO
CONTINUE FACT DISCOVERY
CUTOFF FROM APRIL 9, 2014 TO
MAY 30, 2014; ORDER
JUDGE: Hon. Morrison C. England, Jr.
COMPLAINT FILED: December 7, 2012
TRIAL DATE: February 9, 2015

Defendants.

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs Pascual

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Trujillo, Leticia Trujillo, and Gregory Trujillo; and Defendants Nationwide Insurance Company

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of America, Nationwide Mutual Insurance Company, and Nationwide Sales Solutions, Inc.;
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STIPULATION TO CONTINUE FACT DISCOVERY CUTOFF DATE & ORDER
Case No. 2:12-CV-02958 MCE CMK

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through their respective counsel that, pursuant to Federal Rules of Civil Procedure Rule 29 and

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16(b), the cutoff date for fact discovery, April 9, 2014 (Item IV of the Pretrial Scheduling Order,

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Docket #25), be extended to May 30, 2014.

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The parties have exchanged Initial Disclosures and written discovery, and have scheduled

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depositions. In light of the number of fact witnesses and counsel’s scheduling conflicts,

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however, the parties cannot reasonably complete all depositions and any subsequent further

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written discovery by the current April 9, 2014 cutoff. This extension of less than two months

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will not interfere with the date set for completing all discovery or affect any other dates in the

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Pretrial Scheduling Order.

MEREDITH, WEINSTEIN & NUMBERS, LLP
115 WARD STREET
LARKSPUR, CALIFORNIA 94939

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Based on the foregoing, the parties respectfully request that the Court extend the fact
discovery cutoff from April 9, 2014 to May 30, 2014.

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Respectfully Submitted,

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DATED:

February 26, 2014

STROOCK & STROOCK & LAVAN, LLP

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By:

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/s/
Allan S. Cohen

Attorney for Defendants
Nationwide Insurance Company of America,
Nationwide Mutual Insurance Company,
And Nationwide Sales Solutions, Inc.,

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DATED:

February 26, 2014

MEREDITH, WEINSTEIN & NUMBERS, LLP

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By:

/s/
Barron L. Weinstein

Attorney for Plaintiffs
Pascual Trujillo, Leticia Trujillo,
and Gregory Trujillo

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STIPULATION TO CONTINUE FACT DISCOVERY CUTOFF DATE & ORDER
Case No. 2:12-CV-02958 MCE CMK

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ORDER
For good cause shown, it is hereby ordered that Paragraph IV of this Court’s Scheduling
Order dated August 27, 2013 is amended to extend the fact discovery completion date from April
9, 2014 to May 30, 2014.
IT IS SO ORDERED.
Dated: April 22, 2014

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MEREDITH, WEINSTEIN & NUMBERS, LLP
115 WARD STREET
LARKSPUR, CALIFORNIA 94939

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STIPULATION TO CONTINUE FACT DISCOVERY CUTOFF DATE & ORDER
Case No. 2:12-CV-02958 MCE CMK