Worth v. Nationwide Agribusiness Insurance Company

Filing 17

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 7/28/15 ORDERING that the Deadline for the Parties to complete Mediation pursuant to the Court's Voluntary Dispute Resolution Program is EXTENDED to 12/2/2015.(Mena-Sanchez, L)

1 LEWIS BRISBOIS BISGAARD & SMITH LLP
Julian J. Pardini, Esq. SB# 133878
E-Mail: [e-mail]
2
Stephen J. Liberatore, Esq. SB# 129772
E-Mail: [e-mail]
3
333 Bush Street, Suite 1100
4 San Francisco, California 94104-2872
Telephone:
415.362.2580
415.434.0882
5 Facsimile:
6 Attorneys for Defendant
NATIONWIDE MUTUAL INSURANCE
7 COMPANY, sued herein as “NATIONWIDE
AGRIBUSINESS INSURANCE COMPANY”
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9

UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

11 NATE WORTH,
Plaintiff,

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CASE NO. 2:14-CV-02068-GEB-AC

v.

14 NATIONWIDE AGRIBUSINESS INSURANCE
COMPANY, AN IOWA CORPORATION
15 QUALIFIED TO DO BUSINESS IN
CALIFORNIA AKA NATIONWIDE MUTUAL
16 INSURANCE AKA ALLIED INSURANCE AND
DOES 1 THROUGH 100 INCLUSIVE,
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Defendants.
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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE TO
COMPLETE MEDIATION PURSUANT
TO COURT’S VOLUNTARY DISPUTE
RESOLUTION PROGRAM

Complaint Filed: July 28, 2014

Plaintiff NATE WORTH (“Plaintiff”) and NATIONWIDE MUTUAL INSURANCE

20 COMPANY, sued herein as “NATIONWIDE AGRIBUSINESS INSURANCE COMPANY”
21 (“Defendant”), and collectively referred to hereinafter as “the Parties,” by and through their
22 respective counsel of record stipulate as follows:
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RECITALS
1.

On May 18, 2015, the Parties agreed by stipulation to participate in mediation

25 pursuant to the Court’s “Voluntary Dispute Resolution Program” (“VDRP”).
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2.

On May 18, 2015, the Court ordered the Parties to participate in VDRP mediation.

27

3.

On June 4, 2015, the Court appointed Richard Caufield to act as the neutral

28 attorney with respect the Parties’ VDRP mediation.
4813-3825-5909.1

2:14-CV-02068-GEB-AC
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE MEDIATION
PURSUANT TO COURT’S VOLUNTARY DISPUTE RESOLUTION PROGRAM

4.

1

Per the Court’s Local Rule 271(j)(1), the Parties were to complete the VDRP

2 mediation no later than September 3, 2015.
5.

3

However, due to the Parties’ respective counsel’s trial calendars and Mr. Caufield’s

4 request that the mediation be held on a Friday, the Parties cannot complete the mediation prior to
5 the September 3, 2015. In consultation with Mr. Caufield, counsel for the Parties are endeavoring
6 to schedule the mediation for Friday, October 2, 2015, or Friday, October 16, 2015.
7

STIPULATION

8

WHEREFORE, the Parties, by and through their respective counsel of record, hereby

9 stipulate as follows:
That the Parties, jointly, by and through their respective counsel of record, request that the

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11 Court extend the deadline for the Parties to complete mediation pursuant to VDRP, presently set
12 for September 3, 2015, an additional 90 days to December 2, 2015.
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14

Respectfully submitted,

15 Dated: July __, 2015

Law Office of James L. Brunello

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17

By

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James L. Brunello
Karen Pine
Attorneys for Plaintiff
NATE WORTH

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20
21 Dated: July __, 2015

LEWIS BRISBOIS BISGAARD & SMITH LLP

22
By

____________________
Julian J. Pardini
Stephen J. Liberatore
Attorneys for Defendant
NATIONWIDE MUTUAL INSURANCE
COMPANY, sued herein as “NATIONWIDE
AGRIBUSINESS INSURANCE COMPANY”

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27 / / /
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4813-3825-5909.1

2:14-CV-02068-GEB-AC
2
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE MEDIATION
PURSUANT TO COURT’S VOLUNTARY DISPUTE RESOLUTION PROGRAM

1

ORDER

2

Having read and considered the Parties’ stipulation, set forth above,

3

THE COURT HEREBY ORDERS that the deadline for the Parties to complete

4 mediation pursuant to the Court’s Voluntary Dispute Resolution Program be, and hereby is,
5 EXTENDED to December 2, 2015.
6
7

IT IS SO ORDERED.

8 Dated: July 28, 2015
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4813-3825-5909.1

2:14-CV-02068-GEB-AC
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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE MEDIATION
PURSUANT TO COURT’S VOLUNTARY DISPUTE RESOLUTION PROGRAM