Pinn v. Fidelity National Insurance Company

Filing 10

STIPULATION and ORDER to Modify Scheduling Order to Continue the Discovery cutoff date for 90 days signed by District Judge Troy L. Nunley on 9/24/14. The Discovery cutoff is CONTINUED to 12/30/2014.(Mena-Sanchez, L)

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Michael F. Keddy, CSB No. 66395
Law Offices of Michael F. Keddy
3620 American River Drive, Suite 230
Sacramento, CA 95864
Tel: [phone] Fax: [phone]

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-and-

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Gregory P. O’Dea, CSB No. 110966
LONGYEAR, O’DEA & LAVRA, LLP
3620 American River Drive, Suite 230
Sacramento, California 95864-5923
Tel: [phone] Fax: [phone]

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Attorneys for Defendant, Fidelity National Insurance Company

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William J. Brown, III, CSB No. 86002
P.O. Box 231216
Encinitas, CA 92023-1216
Tel: [phone] Fax: [phone]

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Attorney for Plaintiff, Richard A. Pinn

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF THE STATE OF CALIFORNIA

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RICHARD A. PINN,
Plaintiff,
v.
FIDELITY NATIONAL INSURANCE
COMPANY; and DOES 1 through 30,
inclusive,
Defendants.

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CASE NO. 2:13-cv-1820-TLN AC
STIPULATION AND ORDER TO
MODIFY SCHEDULING ORDER TO
CONTINUE THE DISCOVERY CUTOFF
DATE FOR 90 DAYS

ALL PARTIES, by and through their respective counsel, hereby stipulate and request

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that the Court order a modification of the current Pretrial Scheduling Order to continue the

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discovery cutoff date for an additional 90 days.

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Although the parties have proceeded diligently to conduct discovery in this matter, there

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remain several depositions that have not been able to be taken due to difficulty locating

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witnesses, the availability of witnesses, and scheduling conflicts.

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Stipulation and Order to Modify Scheduling Order to Continue the Discovery Cutoff Date for 90 Days
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By this request, the parties seek only to continue the discovery cutoff date and do not
request that any other deadline in this case be continued, including the deadline for disclosure of
expert witnesses, the deadline for the hearing of dispositive motions, the pretrial conference, or
the trial itself. No prior request has been made for continuance in this matter.
Therefore, the parties agree and stipulate, and request that the Court approve a
modification of the Scheduling Order to allow discovery to continue for an additional 90 days, or
until December 30, 2014.

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Respectfully submitted,

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Dated: September 23, 2014

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/s/ William J. Brown, III
_________________________________________
WILLIAM J. BROWN, III
Attorney for Plaintiff
RICHARD A. PINN

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Dated: September 23, 2014

LONGYEAR, O'DEA & LAVRA, LLP
/s/ Gregory P. O’Dea
By:__________________________________
GREGORY P. O’DEA
Attorneys for Defendant,
FIDELITY NATIONAL INSURANCE COMPANY

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Stipulation and Order to Modify Scheduling Order to Continue the Discovery Cutoff Date for 90 Days
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ORDER

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IT IS SO ORDERED:
The discovery cutoff is continued to December 30, 2014.

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Dated: September 24, 2014

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Troy L. Nunley
United States District Judge

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Stipulation and Order to Modify Scheduling Order to Continue the Discovery Cutoff Date for 90 Days
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