Banga v. Ameriprise Auto & Home Insurance Agency

Filing 119

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 2/24/2021 MODIFYING The Scheduling Order as follows: Banga shall have until 5/3/2021 to conduct the Rule 30(b)(6) depositions of Defendants and the deadline for hearings on dispositive Motions shall be CONTINUED 6/9/2021. (Mena-Sanchez, L)

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Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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JORDAN S. ALTURA (SBN: 209431)
[e-mail]
JENNIFER N. WAHLGREN (SBN: 249556)
[e-mail]
GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
AMERIPRISE AUTO & HOME INSURANCE AGENCY, INC. and
IDS PROPERTY CASUALTY INSURANCE COMPANY
Kamlesh Banga
P.O. Box 5656
Vallejo, CA 94591
Telephone: (707) 342 – 1692
PLAINTIFF IN PRO PER

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KAMLESH BANGA,

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Plaintiff,
vs.
AMERIPRISE AUTO & HOME INSURANCE
AGENCY AND DOES 1 through 10 inclusive

Case No. 2:18-cv-01072-MCE-AC
STIPULATION TO EXTEND
DEADLINES FOR DEPOSITIONS
AND DISPOSITIVE MOTIONS;
[PROPOSED] ORDER

Defendant.

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STIPULATION TO EXTEND DEADLINES FOR DEPOSITIONS AND DISPOSITIVE
MOTIONS; [PROPOSED] ORDER

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Plaintiff Kamlesh Banga, in pro per (“Banga”), and Defendants Ameriprise Auto & Home

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Insurance Agency, Inc. and IDS Property Casualty Insurance Company (“IDS”) (collectively

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“Defendants”), by and through their attorneys of record, hereby stipulate as follows:

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WHEREAS, on December 17, 2020, the Court issued an order that extended the discovery

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deadline to March 3, 2021, and the deadline for dispositive motions to April 7, 2021. (ECF No.

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91.) No trial date has been set for this action.

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WHEREAS, IDS’ witnesses1 are directly involved in handling extensive claims resulting

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from the catastrophic freeze and power shut off events that recently occurred in Texas. It would

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be overly burdensome on the witnesses to prepare and sit for deposition within the next few weeks,

Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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while they are working to compensate victims.

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WHEREAS, the parties have met and conferred, and agree that Banga should be permitted

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to take the Rule 30(b)(6) depositions of Defendants after the close of discovery. The parties agree

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that Banga should have until May 3, 2021 to complete the Rule 30(b)(6) depositions of Defendants,

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and the deadline for hearings on dispositive motions should be continued to June 9, 2021.

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WHEREAS, the parties are not requesting a continuance of any other deadlines, including
the deadline to complete discovery other than the Rule 30(b)(6) depositions of Defendants.

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WHEREAS, this is the parties’ second stipulation for a continuance of deadlines.

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THEREFORE, IT IS HEREBY STIPULATED AND AGREED:

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Banga should have until May 3, 2021 to complete the Rule 30(b)(6) depositions of

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Defendants and the deadline for hearings on dispositive motions should be continued to June 9,

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2021.

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SO STIPULATED.

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Dated: February 23, 2021

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By /s/ Kamlesh Banga (as authorized on 2.23.21)
Kamlesh Banga
PLAINTIFF IN PRO PER

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One of IDS’ Rule 30(b)(6) witnesses has also been designated as the Rule 30(b)(6) witness on
behalf of Agency.
-1STIPULATION TO EXTEND DEADLINES FOR DEPOSITIONS AND DISPOSITIVE
MOTIONS; ORDER

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Dated: February 23, 2021

GORDON REES SCULLY MANSUKHANI, LLP

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By /s/ Jennifer N. Wahlgren
Jordan S. Altura
Jennifer N. Wahlgren
Attorneys for Defendants
AMERIPRISE AUTO & HOME INSURANCE
AGENCY, INC. and IDS PROPERTY
CASUALTY INSURANCE COMPANY

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[PROPOSED] ORDER

Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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The Court, having reviewed the stipulation, hereby finds good cause to modify the Status

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Order in this action as follows: Banga shall have until May 3, 2021 to conduct the Rule 30(b)(6)

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depositions of Defendants and the deadline for hearings on dispositive motions shall be continued

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to June 9, 2021.

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IT IS SO ORDERED.

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Dated: February 24, 2021

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-2STIPULATION TO EXTEND DEADLINES FOR DEPOSITIONS AND DISPOSITIVE
MOTIONS; ORDER