Driver v. Pape Kenworth et al

Filing 73

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 5/23/22 CONTINUING deadlines: Fact Discovery Cut-Off: 8/31/2022 ; Deadline for Initial Designation of Expert Witnesses: 11/30/2022; Deadline for Designation of Rebuttal Expert Witnesses: 12/30/2022; Expert Discovery Cut-Off: 2/15/2023; Dispositive Motion Hearing Cut Off: 4/17/2023. (Kaminski, H)

1
2
3
4
5
6

CHARLES S. PAINTER (SBN 89045)
REBECCA L. MENENDEZ (SBN 262487)
ERICKSEN ARBUTHNOT
100 Howe Avenue, Suite 110 South
Sacramento, CA 95825-8201
[phone] Telephone
[phone] Facsimile
Attorneys for Defendant/Third Party Plaintiff,
PAPÉ TRUCKS, INC.

7

UNITED STATES DISTRICT COURT

8

EASTERN DISTRICT OF CALIFORNIA

9
10

ROGER DRIVER,
Plaintiff,

11
12

vs.

13

PAPÉ TRUCKS, INC. AN OREGON
CORPORATION,

14

Defendant.

15
16

AND RELATED CROSS-ACTIONS

17

) Case No.: 2:17-CV-01968- KJN
)
)
) STIPULATION AND [PROPOSED]
) ORDER TO EXTEND DEADLINES
)
)
)
)
)
)
)
)
)

18

WHEREAS the court previously ordered the deadlines listed below, pursuant to a prior

19

stipulation between the parties; whereas the parties, through their respective counsel, have

20

recently met and conferred; whereas the parties have been working diligently to complete the

21

needed discovery of witnesses located all over the country; whereas COVID-19 has delayed the

22

completion of discovery; whereas the parties have full trial calendars due to the bottleneck of

23

trials that COVID-19 has created; whereas based on the foregoing, the parties have agreed and

24

stipulated to continue the following deadlines:

25

///

26

///

27

///

28

///
STIPULATION AND ORDER TO EXTEND DEADLINES
- 1 17-089/PLEADINGS.026
CSP/RLM:kf

1
2
3
4
5
6
7
8
9

Event
1.
2.
3.
4.
5.
6.
7.

Current Date

Fact Discovery Cut−Off
May 31, 2022
Deadline for Initial Designation of Expert
August 31, 2022
Witnesses
Deadline for Designation of Rebuttal
September 30, 2022
Expert Witnesses
Expert Discovery Cut-Off
November 15, 2022
Dispositive Motion Hearing Cut−Off
January 17, 2023
Final Pre-Trial Conference
Not set
Jury Trial
Not set

Proposed New Date
August 31,2022
November 30, 2022
December 30, 2022
February 15, 2023
April 17, 2023
Not set
Not set

IT IS SO STIPULATED:

10
11

DATED: May 18, 2022
ERICKSEN ARBUTHNOT

12
13

By

14
15
16
17
18

DATED: May 18, 2022
CUTTER LAW P.C.

19

By

20
21
22
23
24

27

/s/Celine E. Cutter as
Authorized on 5/18/22
C. BROOKS CUTTER
CELINE CUTTER
Attorneys for Plaintiff
ROGER DRIVER

DATED: May 18, 2022
WOOD SMITH HENNING & BERMAN,
LLP

25
26

CHARLES S. PAINTER
REBECCA L. MENENDEZ
Attorneys for Defendant/Third Party Plaintiff
PAPÉ TRUCKS, INC.

By

28
STIPULATION AND ORDER TO EXTEND DEADLINES
- 2 17-089/PLEADINGS.026
CSP/RLM:kf

/s/ Matthew A. Williams as
Authorized on 5/18/22
MATTHEW A. WILLIAMS
Attorneys for Third-Party Defendant
JOMAR INVESTMENTS, INC.

1
2

DATED: May 18, 2022
GIBSON ROBB & LINDH LLP

3
4

By

5
6
7
8
9

IT IS SO ORDERED.

10
11

Dated: May 23, 2022

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND ORDER TO EXTEND DEADLINES
- 3 17-089/PLEADINGS.026
CSP/RLM:kf

/s/R. Hudson Hollister as
Authorized on 3/11/22
JOSHUA E. KIRSCH
R. HUDSON HOLLISTER
Attorneys for Plaintiff In Intervention
ACCIDENT FUND INSURANCE
COMPANY OF AMERICA