Nationwide Insurance Company of America v. Marquez

Filing 19

ORDER signed by William H. Orrick, III on 5/9/2017 ORDERING Discovery due by 9/30/2017; Expert Disclosure due by 8/15/2017; the deadline for dispositive motions to be heard is set for 10/25/2017; all other dates will remain the same as provided for in the 1/3/2017 Civil Minutes and Pretrial Schedule Order. (Reader, L)

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RYAN L. DOSTART, ESQ. / SBN: 281539
DREYER BABICH BUCCOLA WOOD CAMPORA, LLP
20 Bicentennial Circle
Sacramento, CA 95826
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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NATIONWIDE INSURANCE COMPANY OF
AMERICA,

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Plaintiff,

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v.

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Case No.: 2:16-cv-01978-WHO
STIPULATION FOR THE PARTIES TO
MODIFY THE PRETRIAL SCHEDULE
AND EXTEND DISCOVERY
DEADLINES; ORDER

CYNTHIA MARQUEZ,
Defendant.
Judge:

Hon. William H. Orrick

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Pursuant to Rules 16(b) (4) and 29 of the Federal Rules of Civil Procedure, Defendant

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CYNTHIA MARQUEZ and Plaintiff NATIONWIDE INSURANCE COMPANY OF AMERICA, by and

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through their attorneys of record, subject to the approval of the Court and good cause present,

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hereby stipulate to modify the Pretrial Schedule Order dated January 3, 2017, and extend the

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time for discovery deadlines previously set in this matter.
The parties submit that there is good cause for the proposed modification of this Court’s
Pretrial Scheduling order for the following reasons:

The parties have discussed conducting

expert inspections of Ms. Marquez’s bicycle and the clothing/helmet she was wearing at the
time of the subject incident and believe these inspections could facilitate early resolution of this
claim short of trial. The parties have exchanged written discovery and conducted depositions
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STIPULATION FOR THE PARTIES TO MODIFY THE PRETRIAL SCHEDULE AND EXTEND DISCOVERY
DEADLINES; ORDER

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of witnesses and emergency personnel, but need additional time in order to coordinate the

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inspection and conduct any additional follow-up discovery precipitated by the inspection.

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THEREFORE, THE PARTIES STIPULATE AND AGREE AND RESPECTFULLY REQUEST the
following modifications to the scheduling order:
The date for completion of discovery is currently scheduled for August 15, 2017. The
parties request an extension of this deadline to September 30, 2017.
The expert disclosure deadline is currently scheduled for July 3, 2017.

The parties

request an extension of this deadline to August 15, 2017.
The deadline for dispositive motions to be heard is currently scheduled for October 4,
2017. The parties request an extension of this deadline to October 25, 2017.
All other dates will remain the same as provided for in the January 3, 2017 Civil Minutes
and Pretrial Schedule Order.
DATED: May 4, 2017

BECHERER KANNETT & SCHWEITZER

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By:

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DATED: May 4, 2017

/s/ David Borovsky
DAVID BOROVSKY
Attorney for Plaintiff

DREYER BABICH BUCCOLA WOOD CAMPORA, LLP

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By:

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/s/ Ryan L. Dostart
RYAN L. DOSTART
Attorney for Defendant

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IT IS SO ORDERED:

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DATED: May 9, 2017

___________________________________
HON. WILLIAM H. ORRICK
UNITED STATES DISTRICT JUDGE

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STIPULATION FOR THE PARTIES TO MODIFY THE PRETRIAL SCHEDULE AND EXTEND DISCOVERY
DEADLINES; ORDER