American Guarantee and Liability Insurance Company v. Charlotte Pipe and Foundry Company

Filing 33

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr., on 12/30/18 ORDERING that the designation of expert witnesses is due by 1/2/2019 and the last day to hear dispositive motions is 4/8/2019. (Kastilahn, A)

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TIMOTHY J. MCCAFFERY, SBN 154668
JASON B. SHANE, SBN 253908
MCCAFFERY | HOSKING LLP
1777 Botelho Drive, Suite 360
Walnut Creek, CA 94596-5084
Telephone:
925.705.7358
Facsimile:
925.705.7381
[e-mail]
[e-mail]
Attorneys for Defendant
CHARLOTTE PIPE AND FOUNDRY COMPANY
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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1777 Botelho Drive, Suite 360
Walnut Creek, CA 94596-5084
510.610.8709

MCCAFFERY | HOSKING LLP

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AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY,
Plaintiff,

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v.
CHARLOTTE PIPE AND FOUNDRY
COMPANY,
Defendant.

Case No. 2:16-CV-00590-MCE-EFB
Assigned to:
Courtroom

Hon Morrison C. England, Jr.
7 (14th Floor)

STIPULATION TO MODIFY PRETRIAL
SCHEDULING ORDER
Action Filed:
Trial Date:

February 2, 2016
None Set

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IT IS HEREBY STIPULATED by and between all parties, through their designated
counsel, that certain dates and other deadlines listed in the Court’s Supplemental Pretrial
Scheduling Order dated October 21, 2016 and subsequently modified pursuant to the Court’s
Order dated November 2, 2017 be continued by approximately 45 days. Good cause exists
for the extension under Rule 16(b) of the Federal Rules of Civil Procedure and Section VIII
of the Supplemental Pretrial Scheduling Order, based upon the parties’ desire to participate in
mediation with mediator John Bates of JAMS on December 19, 2018, following the recent
completion of all non-expert discovery with the exception of a single third-party deposition
that the parties are presently working together to schedule. The parties wish to mediate the
matter before incurring the costs associated with expert disclosures and dispositive motions,
and therefore wish to continue the associated deadlines by approximately 45 days.

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STIPULATION TO MODIFY PRETRIAL SCHEDULING ORDER

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Accordingly, per the instant stipulation, the parties, through their designated counsel,

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request that the Court’s Supplemental Pretrial Scheduling Order dated October 21, 2016 and

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subsequently modified pursuant to the Court’s Order dated November 2, 2017 be modified to

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incorporate the following, revised deadlines:

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Expert Witness Disclosures ..................................... January 2, 2019

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Last Day to Hear Dispositive Motions ......................... April 8, 2019

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Dated: November 7, 2018

SHUMSKY & BACKMAN

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By: _/s/ Eric C. Hanson______________________
ERIC C. HANSON
Attorneys for Plaintiff
AMERICAN GUARANTEE AND LIABILITY
INSURANCE COMPANY

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1777 Botelho Drive, Suite 360
Walnut Creek, CA 94596-5084
510.610.8709

MCCAFFERY | HOSKING LLP

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Dated: November 7, 2018

MCCAFFERY | HOSKING LLP

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By:_/s/ Jason B. Shane_______________________
TIMOTHY J. MCCAFFERY
JASON B. SHANE
Attorneys for Defendant
CHARLOTTE PIPE AND FOUNDRY
COMPANY

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STIPULATION TO MODIFY PRETRIAL SCHEDULING ORDER

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ORDER MODIFYING PRETRIAL SCHEDULING ORDER
The Court, having reviewed the parties’ November 7, 2018 Stipulation to Modify

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Pretrial Scheduling Order, finds that good cause exists for the requested continuance under

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Rule 16(b) of the Federal Rules of Civil Procedure and Section VIII of the Supplemental

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Pretrial Scheduling Order dated October 21, 2016 and subsequently modified pursuant to the

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Court’s Order dated November 2, 2017, based upon the parties’ desire to participate in

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mediation with mediator John Bates of JAMS on December 19, 2018, following the recent

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completion of all non-expert discovery with the exception of a single third-party deposition

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that the parties are presently working together to schedule, and the parties’ wish to mediate
the matter before incurring the costs associated with expert disclosures and dispositive

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1777 Botelho Drive, Suite 360
Walnut Creek, CA 94596-5084
510.610.8709

MCCAFFERY | HOSKING LLP

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motions.

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Accordingly, the Court orders that its Supplemental Pretrial Scheduling Order dated

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October 21, 2016 and subsequently modified pursuant to the Court’s Order dated November

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2, 2017 is hereby modified to incorporate the following, revised deadlines:

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Expert Witness Disclosures ..................................... January 2, 2019

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Last Day to Hear Dispositive Motions ......................... April 8, 2019

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IT IS SO ORDERED.
Dated: December 30, 2018

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STIPULATION TO MODIFY PRETRIAL SCHEDULING ORDER