Driver v. Pape Kenworth et al

Filing 75

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 9/1/2022 CONTINUING the Fact Discovery CutOff due by 10/31/2022.(Perdue, C.)

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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.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ROGER DRIVER,
Plaintiff,

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vs.

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PAPÉ TRUCKS, INC. AN OREGON
CORPORATION,

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINES

Defendant.

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Case No. 2:17-CV-01968-KJN

AND RELATED CROSS-ACTIONS

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

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

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

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

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

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trials that COVID-19 has created; whereas a witness for Jomar has recently had COVID

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preventing the scheduling of their deposition; whereas the only date being amended herein is the

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close of fact discovery; whereas based on the foregoing, the parties have agreed and stipulated to

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continue the following deadlines:

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///

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///
STIPULATION AND ORDER TO EXTEND DEADLINES
- 1 17-089/PLEADINGS.027
CSP/RLM:kf

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Event
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Current Date

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

New Date
October 31, 2022
(same)
(same)
(same)
(same)
Not set
Not set

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IT IS SO STIPULATED:

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DATED: August 30, 2022
ERICKSEN ARBUTHNOT

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By

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DATED: August 30, 2022
CUTTER LAW P.C.

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By

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/s/Celine E. Cutter as
authorized on 8/30/22
C. BROOKS CUTTER
CELINE CUTTER
Attorneys for Plaintiff
ROGER DRIVER

DATED: August 30, 2022
WOOD SMITH HENNING & BERMAN,
LLP

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

By

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STIPULATION AND ORDER TO EXTEND DEADLINES
- 2 17-089/PLEADINGS.027
CSP/RLM:kf

/s/ Matthew A. Williams as
authorized on 8/30/22
MATTHEW A. WILLIAMS
Attorneys for Third-Party Defendant
JOMAR INVESTMENTS, INC.

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DATED: August 30, 2022
GIBSON ROBB & LINDH LLP

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By

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IT IS SO ORDERED.
Dated: September 1, 2022

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STIPULATION AND ORDER TO EXTEND DEADLINES
- 3 17-089/PLEADINGS.027
CSP/RLM:kf

/s/ R. Hudson Hollister as
authorized on 8/30/22
JOSHUA E. KIRSCH
R. HUDSON HOLLISTER
Attorneys for Plaintiff In Intervention
ACCIDENT FUND INSURANCE
COMPANY OF AMERICA