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

Filing 22

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 12/6/2017 CONTINUING deadlines as follows: Discovery shall be completed by 1/18/2018; Initial Expert Disclosures due by 2/18/2018; Rebuttal Expert Disclosures due by 3/16/2018; Dispositive Motions filed by 4/16/2018. (Zignago, K.)

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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
EASTERN DISTRICT OF CALIFORNIA

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Tammy Lynn Logan, an individual,
Plaintiff,

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JOINT STIPULATION AND ORDER TO
CONTINUE DISCOVERY AND
DISPOSITIVE MOTION DEADLINES

vs.

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

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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JOINT STIP AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)

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Pursuant to Local Rule 143 and the Court’s Order Extending Discovery Deadlines (Dkt.

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#17), Plaintiff Tammy Lynn Logan (“Plaintiff”) and Defendants Patriot National, Inc., Patriot

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

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erroneously sued as “Patriot Risk Management, Inc.” (collectively, “Defendants”), by and

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through their counsel of record hereby stipulate and request that the Court enter and Order as

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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”)];
WHEREAS, Defendants removed this action to this Court on June 22, 2016 [Dkt. #1];
WHEREAS, on June 22, 2016 the Court issued an Initial Pretrial Scheduling Order,

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which scheduled deadlines for discovery, disclosure of expert witness and dispositive motions

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[Dkt. #2];

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WHEREAS, the parties sought and the Court approved the parties’ stipulation to extend
all pretrial deadlines to accommodate out of state depositions;
WHEREAS, the Court’s Order set, inter alia, the following deadlines [Dkt. #14]:

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Event
Fact Discovery

New Date
October 18, 2017

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Initial Expert Disclosures

December 18, 2018

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Rebuttal Expert Disclosures

January 16, 2018

Dispositive Motion Filing
Deadline

February 15, 2018

Notice of Trial Readiness

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

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WHEREAS, the parties participated in mediation on October 10, 2017 and were unable
to reach a settlement;
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JOINT STIP AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)

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WHEREAS the parties required additional time to continue negotiations, and to
complete discovery if negotiations are unsuccessful;
WHEREAS, the parties previously sought and the Court approved to extend by 30 days
the fact discovery deadline [Dkt. #17];
WHEREAS, the parties are still engaged in settlement discussions and need additional

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time to continue negotiations, and to complete fact discovery and retain experts if negotiations

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are unsuccessful;

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WHEREAS, the proposed extension to the discovery will not impact the trial date of
this case;
WHEREAS, in light of the above, good cause exists to extend the current discovery,
expert disclosure schedule and dispositive motion 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 deadlines in the Court’s October 30, 2017 Order as follows:
Event
Fact Discovery

Current Date
November 17, 2017

New Date
January 18, 2018

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Initial Expert Disclosures

December 18, 2017

February 18, 2018

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Rebuttal Expert Disclosures

January 16, 2018

March 16, 2018

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Dispositive Motion Filing

February 15, 2017

April 16, 2018

Notice of Trial Readiness

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

No change

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JOINT STIP AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)

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IT IS SO STIPULATED.

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Dated: December 4, 2017

ARIAS SANGUINETTI STAHLE & TORRIJOS, LLP

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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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Dated: December 4, 2017

LITTLER MENDELSON, PC

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

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

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IT IS SO ORDERED.
Dated: December 6, 2017

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JOINT STIP AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES
(CASE NO. 16-CV-01407-MCE-CKD)