Logan v. Patriot National, Inc., et al.

Filing 14

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 6/23/2017 EXTENDING All Pretrial Deadlines: Fact Discovery due by 10/18/2017; Initial Expert Disclosures due by 12/18/2017; Rebuttal Expert Disclosures due by 1/16/2018; and Dispositive Motions filed by 2/15/2018. (Donati, J)

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Mike Arias (CSB #115385)
[e-mail]
Alfredo Torrijos (CSB #222458)
[e-mail]
ARIAS SANGUINETTI STAHLE & TORRIJOS, LLP
6701 Center Drive West, 14th Floor
Los Angeles, CA 90045
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff,
Tammy Lynn Logan
JoAnna L. Brooks (CSB #182986)
[e-mail]
Britney N. Torres (CSB #287019)
[e-mail]
LITTLER MENDELSON, P.C.
Treat Towers
1255 Treat Boulevard, Suite 600
Walnut Creek, CA 94597
Tel: [phone]
Fax: [phone]
Attorneys for Defendants,
Patriot National, Inc., Patriot Risk Services, Inc.,
Patriot Claim Services, Inc., and
Patriot Risk Consultants, Inc.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
Tammy Lynn Logan, an individual,
Plaintiff,

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JOINT STIPULATION AND ORDER
EXTENDING ALL PRETRIAL
DEADLINES

vs.

Patriot National, Inc., a Delaware Corporation;
Patriot Risk Services, Inc., a Delaware
Corporation; Patriot Claim Services, Inc., a
Date Filed: April 22, 2016
Delaware Corporation; Patriot Risk
Trial Date: None set.
Management, Inc., a Delaware Corporation; and
Does 1 through 50, inclusive,
Defendants.

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Case No. 16-cv-01407-MCE-CKD

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JOINT STIPULATION AND ORDER EXTENDING ALL PRETRIAL DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)

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Pursuant to Local Rule 143 and the Court’s June 22, 2016 Initial Pretrial Scheduling

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Order [Dkt. #2], Plaintiff Tammy Lynn Logan (“Plaintiff”) and Defendants Patriot National,

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Inc., Patriot Risk Services, Inc., Patriot Claim Services, Inc., and Patriot Risk Management,

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Inc. (collectively, “Defendants”), by and through their counsel of record hereby stipulate and

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request that the Court enter and Order as follows:

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WHEREAS, Plaintiff commenced this action on April 22, 2016 in the Superior Court of
the State of California for the County of Sacramento [Dkt. #1, Exhibit A (Complaint)];

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WHEREAS, Defendants removed this action to this Court on June 22, 2016 [Dkt. #1];

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WHEREAS, on June 22, 2016 the Court issued an Initial Pretrial Scheduling Order,

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which scheduled pretrial deadlines [Dkt. #2];
WHEREAS, on April 21, 2017, Plaintiff and Defendants filed a Joint Stipulation and
[Proposed] Order Extending Discovery Deadlines [Dkt. #10];
WHEREAS, on April 24, 2017, the Court issued an Order Extending Discovery
Deadlines [Dkt. # 12], setting, inter alia, the following deadlines:
Event
Fact Discovery

Date
June 20, 2017

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Initial Expert Disclosures

August 18, 2017

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Rebuttal Expert Disclosures

September 18, 2017

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Dispositive Motion Filing Deadline

October 18, 2017

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Notice of Trial Readiness

30 days after receiving
Court’s ruling on the last filed
dispositive motion

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WHEREAS, Plaintiff has taken the depositions of six of Defendants’ employees who
are located out-of-state and Defendants have taken one day of Plaintiff’s deposition;
WHEREAS, the Parties are interested in mediating this case and need to extend pretrial
deadlines in order to allow sufficient time to do so;
WHEREAS, the Parties have agreed to proceed with private mediation based on the
discovery completed to date and believe that judicial economy is best served by extending the
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JOINT STIPULATION AND ORDER EXTENDING ALL PRETRIAL DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)

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pretrial deadlines, including the dispositive motion filing deadline, in order to allow sufficient

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time to do so.;

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WHEREAS, the Parties may require additional time to complete further depositions and
engage in other discovery;

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WHEREAS, no trial date has been set for this case;

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WHEREAS, the Parties seek to extend by 120 days all pretrial deadlines (including the

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fact discovery, initial expert disclosures, rebuttal expert disclosures, dispositive motion filing,

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and notice of trial readiness deadlines) previously set by the Court;

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WHEREAS, in light of the above, good cause exists to extend the current discovery and
expert disclosure schedule;

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NOW THEREFORE, in consideration of the foregoing, the parties, by and through

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their undersigned counsel, hereby stipulate, agree and request that the Court enter an Order

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amending the pretrial deadlines set forth in the Court’s April 24, 2017 Order as follows:

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Event
Fact Discovery

Current Date
June 20, 2017

New Date
October 18, 2017

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Initial Expert Disclosures

August 18, 2017

December 18, 2017

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Rebuttal Expert Disclosures

September 18, 2017

January 16, 2018

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October 18, 2017

February 15, 2018

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Dispositive Motion Filing
Deadline

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Notice of Trial Readiness

30 days after receiving
Court’s ruling on the last
field dispositive motions

No change.

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JOINT STIPULATION AND ORDER EXTENDING ALL PRETRIAL DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)

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IT IS SO STIPULATED.

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Dated: June 20, 2017

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By: /s/ Alfredo Torrijos
Mike Arias, Esq.
Alfredo Torrijos, Esq.

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Attorneys for Plaintiff
Tammy Lynn Logan

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ARIAS SANGUINETTI STAHLE & TORRIJOS, LLP

Dated: June 20, 2017

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LITTLER MENDELSON
By: /s/ Britney N. Torres
JoAnna L. Brooks, Esq.
Britney N. Torres, Esq.,

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Attorneys for Defendants
Patriot National, Inc., Patriot Risk Services, Inc.,
Patriot Claim Services, Inc., and
Patriot Risk Consultants, Inc.

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IT IS SO ORDERED.

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Dated: June 23, 2017

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JOINT STIPULATION AND ORDER EXTENDING ALL PRETRIAL DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)