CSAA Insurance Exchange v. Broan-NuTone LLC

Filing 49

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 10/18/2018 CONTINUING the hearing re 42 Motion to Compel to 11/14/2018 at 10:00 AM in Courtroom 26 (AC) before Magistrate Judge Allison Claire. (Zignago, K.)

1 Krsto Mijanovic (Bar No. 205060)
[e-mail]
2 Steven A. Scordalakis (Bar No. 293212)
[e-mail]
3 HAIGHT BROWN & BONESTEEL LLP
555 South Flower Street, Forty-Fifth Floor
4 Los Angeles, California 90071
Telephone: [phone]
5 Facsimile: 213.542.8100
6 Attorneys for Defendant,
BROAN-NUTONE LLC
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Alan J. Jang (SBN 83409)
8 Sally Noma (SBN 264774)
Jang & Associates, LLP
9 1766 Lacassie Avenue, Suite 200
Walnut Creek, California 94596
10 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Plaintiff,
12 CSAA INSURANCE EXCHANGE
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION
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CSAA INSURANCE EXCHANGE, as
17 subrogee of Pedro Casteneda, Maria
DeRodriguez, Tongo Inthilath; Andrew &
18 Dena Savage; Audry Ngo,
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Case No. 2:16-CV-02929-TLN-AC
PARTIES’ STIPULATION AND
REQUEST TO CONTINUE PLAINTIFF
CSAA INSURANCE EXCHANGE’S
MOTION TO COMPEL DEPOSITION OF
30(B)(6) DEPONENT

Plaintiff,
v.

Date: October 31, 2018
Time: 10:00 a.m.
Courtroom: 26, 8th Floor
Judge: Honorable Allison Claire

21 BROAN-NUTONE LLC and DOES 1 through
50, inclusive,
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Defendants.
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Trial: June 3, 2019

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TO THE HONORABLE COURT, plaintiff CSAA Insurance Exchange (“Plaintiff”), and

27 Defendant Broan-NuTone LLC (“Defendant”) (collectively the “Parties”), by and through their
28 respective counsel of record, hereby stipulate, agree, and request that the Court continue the hearing
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1 on Plaintiff’s Motion to Compel Deposition of 30(B)(6) Deponent (ECF No. 42), for which good
2 cause exists, as follows:
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WHEREAS, on June 21, 2018, Plaintiff filed its motion to compel the deposition of

4 Defendant’s Person Most Knowledgeable. (ECF No. 28.) Thereafter, the Parties came to an
5 informal resolution, and Plaintiff withdrew its motion. (ECF No. 30.)
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WHEREAS, since that time, the Parties have been unable to agree when a deponent must

7 be produced.
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WHEREAS, as a result of this disagreement, on September 26, 2018, Plaintiff renewed its

9 motion to compel the second deposition of Defendant’s Person Most Knowledgeable. (ECF No.
10 42.) Plaintiff provided Defendant its final draft Joint-Statement setting forth Plaintiff’s position on
11 October 16, 2018. Thereafter, counsel for the Parties met and conferred, whereby counsel for
12 Defendant requested additional time to participate in the drafting of the Joint-Statement. Plaintiff
13 has agreed.
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WHEREAS, as part of the meet and confer efforts, counsel for Defendant called and

15 obtained this Court’s availability for continuing the motion. Counsel for defendant was informed
16 that the hearing date of November 14, 2018 was available.
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THEREFORE, the Parties now agree, and request, that this Court continue the hearing on

18 Plaintiff’s Motion to Compel the Second Deposition of Defendant’s Person Most Knowledgeable
19 (ECF No. 42) until November 14, 2018.
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21 Dated: October 17, 2018

HAIGHT BROWN & BONESTEEL LLP

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By:

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/s/ Krsto Mijanovic
Krsto Mijanovic
Steven A. Scordalakis
Attorneys for Defendant
BROAN-NUTONE LLC

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Dated: October 17, 2018

Jang & Associates, LLP

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By:

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/s/ Sally Noma
Alan J. Jang
Sally Noma
Attorneys for Plaintiff,
CSAA INSURANCE EXCHANGE

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[PROPOSED] ORDER

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COME NOW, the Parties’ Stipulation and Request to Continue the Hearing on Plaintiff’s

3 Motion to Compel the Deposition of 30(B)(6) Deponent came before the Court. Having found
4 good cause, this Court continues the hearing on the motion (ECF No. 42) until November 14,
5 2018.
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IT IS SO ORDERED

7 Dated: October 18, 2018
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