Duncan v. State Farm Mutual Automobile Insurance Company
Filing
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STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 09/27/19 RESETTING the following dates: Dispositive Motion Hearing: 02/07/20; Complete VDRP: 03/06/20; Discovery Cut-Off: 04/17/20; Expert Disclosures: 05/15/20; Expert Reports: 06/02/20; Expert Discovery Cut-Off: 07/02/20. (Benson, A.)
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STEPHEN M. HAYES (SBN 83583)
STEPHEN P. ELLINGSON (SBN 136505)
JAMIE A. RADACK (SBN 221000)
HAYES SCOTT BONINO ELLINGSON
GUSLANI SIMONSON & CLAUSE LLP
999 Skyway Road, Suite 310
San Carlos, CA 94070
Telephone: 650.637.9100
Facsimile: 650.637.8071
Attorneys for Defendant
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
RACHEL RENNO (SBN 272558)
FOOS GAVIN LAW FIRM, P.C.
3947 Lennane Drive, Suite 120
Sacramento, CA 95834
Telephone: 916.779.3500
Facsimile: 916.779.3508
Attorneys for Plaintiff
RAVEN DUNCAN
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
RAVEN DUNCAN, an individual,
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CASE NO. 2:18-cv-01174-KJM-AC
Plaintiff,
STIPULATION AND ORDER TO
PARTIALLY REVISE THE COURT’S
OCTOBER 10, 2018 PRETRIAL
SCHEDULING ORDER AND DEADLINE TO
COMPLETE VDRP
vs.
STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY, a corporation; and DOES 1
through 25, inclusive,
Defendants.
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Pursuant to Rule 16(b) of the Federal Rules of Civil Procedure, plaintiff Raven Duncan and
State Farm Mutual Automobile Insurance Company (“State Farm,”) by and through their respective
counsel, hereby stipulate to partially revise the Court’s October 10, 2018 Pretrial Scheduling Order
and the deadline to complete VDRP as follows:
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1066785
-1STIPULATION AND ORDER TO REVISE THE COURT’S SCHEDULING ORDER
CASE NO. 2:18-cv-01174-KJM-AC
I.
RECITALS
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Pursuant to the Court’s October 10, 2018 Pretrial Scheduling Order, State Farm and
4 plaintiff began engaging in thorough meet and confer discussions retarding State Farm’s motion for
5 summary judgment, or in the alternative, partial summary judgment (“Motion”) on September 25,
6 2019.
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During the meet and confer process related to the Motion, counsel raised issues that
8 require further investigation by the parties.
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3.
Also during the meet and confer process related to the Motion, the parties engaged in
10 discussions regarding the potential for settlement.
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4.
For the purpose of potentially narrowing the issues to be presented in State Farm’s
12 Motion, and to further explore the potential for settlement, the parties agreed to request leave of the
13 Court to continue the Pretrial Scheduling Order and deadline to complete VDRP for 90 days.
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Accordingly, the parties hereby stipulate to partially revising the Court’s Pretrial
15 Scheduling Order and deadline to complete VDRP as follows:
II.
STIPULATION
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The parties hereby stipulate, and request approval of the following revisions to the Court’s
Pretrial Scheduling Order and deadline to complete VDRP:
Event
Current Deadline
Requested New Deadline
Dispositive Motion Hearing
November 15, 2019
February 14, 2019
Complete VDRP
December 6, 2019
March 6, 2020
Discovery Cut-Off
January 17, 2020
April 17, 2020
Expert Disclosures
February 17, 2020
May 15, 2020
Expert Reports
March 2, 2020
June 2, 2020
Expert Discovery Cut-Off
April 2, 2020
July 2, 2020
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1066785
-2STIPULATION AND ORDER TO REVISE THE COURT’S SCHEDULING ORDER
CASE NO. 2:18-cv-01174-KJM-AC
1 Dated: September 30, 2019
FOOS GAVIN LAW FIRM, P.C.
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By
/S/ Rachel Renno
RACHEL RENNO
Attorneys for Plaintiff
RAVEN DUNCAN
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6 Dated: September 30, 2019
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HAYES SCOTT BONINO ELLINGSON GUSLANI
SIMONSON & CLAUSE LLP
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By
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/S/ Jamie A. Radack
STEPHEN M. HAYES
STEPHEN P. ELLINGSON
JAMIE A. RADACK
Attorneys for Defendant
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
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ORDER
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The Court, having reviewed the parties’ Stipulation to Partially Revise the Court’s Pretrial
15 Scheduling Order and deadline to complete VDRP, hereby GRANTS the parties’ request. The new
16 deadlines are as follows:
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Event
Previous Deadline
New Deadline
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Dispositive Motion Hearing
November 15, 2019
February 7, 2020
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Complete VDRP
December 6, 2019
March 6, 2020
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Discovery Cut-Off
January 17, 2020
April 17, 2020
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Expert Disclosures
February 17, 2020
May 15, 2020
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Expert Reports
March 2, 2020
June 2, 2020
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Expert Discovery Cut-Off
April 2, 2020
July 2, 2020
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IT IS SO ORDERED.
25 Dated: September 27, 2019.
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UNITED STATES DISTRICT JUDGE
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1066785
-3STIPULATION AND ORDER TO REVISE THE COURT’S SCHEDULING ORDER
CASE NO. 2:18-cv-01174-KJM-AC
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